Letter Sequence Supplement |
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TAC:MD9483, Addition of LCO 3.0.8, Inoperability of Snubbers (Open) |
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Category:Letter
MONTHYEARIR 05000368/20253012024-09-0909 September 2024 Notification of NRC Initial Operator Licensing Examination 05000368/2025301 IR 05000313/20240112024-09-0505 September 2024 Comprehensive Engineering Team Inspection Report 05000313/2024011 and 05000368/2024011 ML24239A3972024-08-23023 August 2024 Rssc Wire & Cable LLC Dba Marmon - Part 21 Final Notification - 57243-EN 57243 IR 05000313/20240052024-08-21021 August 2024 Updated Inspection Plan for Arkansas Nuclear One – Units 1 and 2 (Report 05000313/2024005, 05000368/2024005) ML24198A0722024-08-21021 August 2024 Correction to Issuance of Amendment No. 333 Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML24220A2642024-08-20020 August 2024 Entergy Operations, Inc. - Entergy Fleet Project Manager Assignment ML24185A1522024-08-13013 August 2024 Issuance of Amendment Nos. 334, 235, and 215, Respectively, to Revise TSs to Adopt TSTF-205 IR 05000313/20240022024-08-0606 August 2024 Integrated Inspection Report 05000313/2024002 and 05000368/2024002 ML24208A0962024-07-25025 July 2024 57243-EN 57243 - Rssc Wire & Cable LLC, Dba Marmon - Part 21 Notification ML24101A1792024-06-25025 June 2024 Issuance of Amendment No. 333 Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML24143A0632024-05-22022 May 2024 Notification of Inspection (NRC Inspection Report 05000368/2024003) and Request for Information IR 05000313/20240012024-05-0808 May 2024 Integrated Inspection Report 05000313/2024001 and 05000368/2024001 ML24128A2472024-05-0808 May 2024 Project Manager Assignment ML24017A2982024-04-18018 April 2024 Summary of Regulatory Audit Regarding the License Amendment Request to Revise Technical Specifications to Adopt TSTF 505, Revision 2, Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b ML24107A0282024-04-17017 April 2024 Notification of Comprehensive Engineering Team Inspection (05000313/2024011 and 05000368/2024011) and Request for Information ML24086A5412024-04-10010 April 2024 Authorization of Request for Alternative ANO1-ISI-037 Regarding Extension of Reactor Vessel Inservice Inspection Interval IR 05000313/20244022024-04-0808 April 2024 Security Baseline Inspection Report 05000313/2024402 and 05000368/2024402 (Full Report) IR 05000313/20244042024-04-0808 April 2024 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection (05000313/2024404 and 05000368/2024404) ML24089A2262024-03-29029 March 2024 Entergy Response to Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Exams ML24075A1712024-03-15015 March 2024 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) ML24074A2892024-03-14014 March 2024 Proof of Financial Protection (10 CFR 140.15) ML24031A6442024-03-14014 March 2024 Issuance of Amendment No. 282 to Modify Technical Specification 3.3.1, Reactor Pressure System (RPS) Instrumentation, Turbine Trip Function on Low Control Oil Pressure ML24102A1342024-03-12012 March 2024 AN1-2024-03 Post Exam Submittal IR 05000313/20230062024-02-28028 February 2024 Annual Assessment Letter for Arkansas Nuclear One- Units 1 and 2 Report 05000313/2023006 and 05000368/2023006 IR 05000313/20243012024-02-27027 February 2024 NRC Initial Operator Licensing Examination Approval 05000313/2024301 IR 05000313/20230042024-02-0808 February 2024 Integrated Inspection Report 05000313/2023004 and 05000368/2023004 and Independent Spent Fuel Storage Installation Inspection Report 07200013/2023002 ML24012A0502024-02-0202 February 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0054 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23326A0392024-01-24024 January 2024 Issuance of Amendment No. 281 Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML24017A1582024-01-17017 January 2024 Submittal of Emergency Plan Revision 50 IR 05000313/20234202024-01-10010 January 2024 Security Baseline Inspection Report 05000313/2023420 and 05000368/2023420 IR 05000313/20234022024-01-0202 January 2024 Security Baseline Inspection Report 05000313/2023402 and 05000368/2023402 ML23349A1672023-12-21021 December 2023 Request for Withholding Information from Public Disclosure ML23354A0022023-12-21021 December 2023 Request for Withholding Information from Public Disclosure ML23348A3572023-12-14014 December 2023 Application to Revise Technical Specifications to Use Online Monitoring Methodology – Slides and Affidavit for Pre-Submittal Meeting ML23352A0292023-12-13013 December 2023 Entergy - 2024 Nuclear Energy Liability Evidence of Financial Protection ML23340A1592023-12-13013 December 2023 Entergy Operations, Inc. - Entergy Fleet Project Manager Assignment IR 05000313/20234052023-12-12012 December 2023 – Security Baseline Inspection Report 05000313/2023405 and 05000368/2023405 ML23341A0832023-12-11011 December 2023 Material Control and Accounting Program Inspection Report 05000313/368/2023404- Cover Letter ML23305A0922023-12-0707 December 2023 Summary of Regulatory Audit Regarding License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b ML23333A1362023-11-29029 November 2023 Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23275A2072023-11-28028 November 2023 Issuance of Amendment No. 280 Removal of Technical Specification Condition Allowing Two Reactor Coolant Pump Operation IR 05000313/20230032023-11-21021 November 2023 Revised - ANO Revised Integrated Inspection Report 05000313/2023003 and 05000368/2023003 and Independent Spent Fuel Storage Installation Inspection Report 07200013/ 2023001 ML23325A1412023-11-21021 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23243B0452023-11-13013 November 2023 Request for Withholding Information from Public Disclosure ML23313A0962023-11-13013 November 2023 Integrated Inspection Report 05000313/2023003 and 05000368/2023003 and Independent Spent Fuel Storage Installation Inspection Report 07200013/2023001 ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV IR 05000313/20230112023-10-10010 October 2023 Commercial Grade Dedication Inspection Report 05000313/2023011 and 05000368/2023011 IR 05000313/20230052023-08-21021 August 2023 Updated Inspection Plan for Arkansas Nuclear One, Units 1 and 2 (Report 05000313/2023005 and 05000368/2023005) - Mid Cycle IR 05000313/20230022023-08-11011 August 2023 Integrated Inspection Report 05000313/2023002 and 05000368/2023002 and Notice of Violation ML23209A6022023-08-0909 August 2023 Regulatory Audit Plan in Support of License Amendment Request to Revise Technical Specifications to Adopt Risk- Informed Completion Times 2024-09-09
[Table view] Category:Technical Specification
MONTHYEAR2CAN042401, Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications2024-04-0404 April 2024 Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications 2CAN112302, Submittal of Amendment 31 to Safety Analysis Report2023-11-16016 November 2023 Submittal of Amendment 31 to Safety Analysis Report 1CAN092301, Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42023-09-21021 September 2023 Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 ML23208A2112023-07-27027 July 2023 Entergy Operations Inc., Application to Revise Technical Specifications to Adopt TSTF-205, Revision of Channel Calibration, Channel Functional Test, and Related Definitions 1CAN032301, License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure2023-03-30030 March 2023 License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure 1CAN122201, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42022-12-22022 December 2022 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 1CAN102202, Application to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation2022-10-31031 October 2022 Application to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation 1CAN102201, Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations2022-10-13013 October 2022 Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations ML21279A2312021-10-0606 October 2021 Application to Revise Technical Specifications to Adopt TSTF-554, Revise Reactor Coolant Leakage Requirements Using the Consolidated Line-Item Improvement 1CAN102101, SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report2021-10-0606 October 2021 SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report ML21266A1612021-09-23023 September 2021 Application to Revise Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated ML21182A1582021-07-0101 July 2021 Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections 1CAN012002, License Amendment Request: Revise Loss of Voltage Relay Allowable Values2020-01-24024 January 2020 License Amendment Request: Revise Loss of Voltage Relay Allowable Values 2CAN121901, License Amendment Request Technical Specification Deletions, Additions, and Relocations2019-12-16016 December 2019 License Amendment Request Technical Specification Deletions, Additions, and Relocations 1CAN061902, Supplemental Change Related to Revise Technical Specifications to Adopt TSTF-567, Add Containment Sump TS to Address GSI-191 Issues2019-06-18018 June 2019 Supplemental Change Related to Revise Technical Specifications to Adopt TSTF-567, Add Containment Sump TS to Address GSI-191 Issues 1CAN031901, License Amendment Request Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an Lco.2019-03-25025 March 2019 License Amendment Request Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an Lco. 1CAN111802, ANO Unit 1 SAR Amendment 28, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report2018-11-12012 November 2018 ANO Unit 1 SAR Amendment 28, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report 2CAN121705, Exigent License Amendment Request Allowance to Exclude Exercise of Control Element Assembly 4 with Respect to Surveillance Requirement 4.1.3.1.2 for the Remainder of Cycle 262017-12-28028 December 2017 Exigent License Amendment Request Allowance to Exclude Exercise of Control Element Assembly 4 with Respect to Surveillance Requirement 4.1.3.1.2 for the Remainder of Cycle 26 2CAN111702, License Amendment Request - Updating the Reactor Coolant System Pressure-Temperature Limits2017-11-20020 November 2017 License Amendment Request - Updating the Reactor Coolant System Pressure-Temperature Limits 1CAN031604, Arkansas, Unit 1 - Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Co2016-03-25025 March 2016 Arkansas, Unit 1 - Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Code 2CAN031602, Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the Asme..2016-03-25025 March 2016 Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the Asme.. 2CAN121502, Application to Revise Technical Specifications to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c, Using the Consolidated Line Item Improvement Process2015-12-22022 December 2015 Application to Revise Technical Specifications to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c, Using the Consolidated Line Item Improvement Process 1CAN121403, License Amendment Request Supplemental ANO-1 Adoption of TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441).2014-12-0505 December 2014 License Amendment Request Supplemental ANO-1 Adoption of TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441). 2CAN101401, Arkansas, Unit 2 - License Amendment Request Supplemental Adoption of Technical Specification Task Force (TSTF)-422, Revision 2, Change in Technical Specifications End States (CE NPSD-1186)2014-10-22022 October 2014 Arkansas, Unit 2 - License Amendment Request Supplemental Adoption of Technical Specification Task Force (TSTF)-422, Revision 2, Change in Technical Specifications End States (CE NPSD-1186) 1CAN011406, Amendment 25 of the ANO Unit 1 Safety Analysis Report2014-01-29029 January 2014 Amendment 25 of the ANO Unit 1 Safety Analysis Report 1CAN121301, Clarification of Proposed Change to Technical Specification 2.1.1.1 Reactor Core Safety Limits2013-12-11011 December 2013 Clarification of Proposed Change to Technical Specification 2.1.1.1 Reactor Core Safety Limits 2CAN061302, License Amendment Request - Supplemental Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-4712013-06-18018 June 2013 License Amendment Request - Supplemental Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 1CAN031306, License Amendment Request, Adoption of Technical Specification Task Force (TSTF)-431, Revision 3 Change in Technical Specifications End States (BAW-2441)2013-03-26026 March 2013 License Amendment Request, Adoption of Technical Specification Task Force (TSTF)-431, Revision 3 Change in Technical Specifications End States (BAW-2441) 2CAN071201, License Amendment Request - Supplemental Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-4712012-07-0909 July 2012 License Amendment Request - Supplemental Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 2CAN041201, License Amendment Request, Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-4712012-04-0404 April 2012 License Amendment Request, Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 1CAN041102, License Amendment Request, Adoption of Technical Specification Task Force (TSTF)513, Revision 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation.2011-04-29029 April 2011 License Amendment Request, Adoption of Technical Specification Task Force (TSTF)513, Revision 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation. 1CAN081001, License Amendment Request, Technical Specification Change Associated with Main Feedwater Isolation Valves2010-08-24024 August 2010 License Amendment Request, Technical Specification Change Associated with Main Feedwater Isolation Valves 2CAN081009, Emergency License Amendment Request Extension of ANO-2 Emergency Diesel Generator Allowed Outage Time2010-08-19019 August 2010 Emergency License Amendment Request Extension of ANO-2 Emergency Diesel Generator Allowed Outage Time 1CAN081002, License Amendment Request, Changes to Technical Specification 3.9.3, Technical Change Traveler - TSTF-312, Rev. 12010-08-10010 August 2010 License Amendment Request, Changes to Technical Specification 3.9.3, Technical Change Traveler - TSTF-312, Rev. 1 2CAN061003, Arkansas Nuclear One, Unit 2 - License Amendment Request, Technical Specification Change to Extend the Type a Test Frequency to 15 Years2010-06-17017 June 2010 Arkansas Nuclear One, Unit 2 - License Amendment Request, Technical Specification Change to Extend the Type a Test Frequency to 15 Years ML1016803802010-06-17017 June 2010 License Amendment Request, Technical Specification Change to Extend the Type a Test Frequency to 15 Years 1CAN021004, Response to Request for Additional Information, Application for Technical Specification Improvement to Adopt TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec.2010-02-28028 February 2010 Response to Request for Additional Information, Application for Technical Specification Improvement to Adopt TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec. 2CAN060903, License Amendment Request, Technical Specification Changes to Relocate Pressurizer Heater Requirements to Technical Requirements Manual2009-06-18018 June 2009 License Amendment Request, Technical Specification Changes to Relocate Pressurizer Heater Requirements to Technical Requirements Manual 2CAN050902, License Amendment Request to Revise Technical Specification 6.6.5, Core Operating Limits Report2009-05-15015 May 2009 License Amendment Request to Revise Technical Specification 6.6.5, Core Operating Limits Report 2CAN050901, License Amendment Request to Revise the Departure from Nucleate Boiling Ratio (DNBR) Safety Limit2009-05-13013 May 2009 License Amendment Request to Revise the Departure from Nucleate Boiling Ratio (DNBR) Safety Limit ENOC-09-00009, Entergy Nuclear Operations, Inc. - License Amendment Request; Proposed Adoption of TSTF-511 Regarding Elimination of Technical Specification Work Hour Restrictions2009-04-27027 April 2009 Entergy Nuclear Operations, Inc. - License Amendment Request; Proposed Adoption of TSTF-511 Regarding Elimination of Technical Specification Work Hour Restrictions 2CAN030902, License Amendment Request, Technical Specification Change to Delete COLR References2009-03-10010 March 2009 License Amendment Request, Technical Specification Change to Delete COLR References 1CAN030901, License Amendment Request on Technical Specification Change to Delete Low Pressurizer Level Limit2009-03-10010 March 2009 License Amendment Request on Technical Specification Change to Delete Low Pressurizer Level Limit 2CAN120801, License Amendment Request Supplemental Regarding Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers and Relocate TS 3.7.8 to the TRM2008-12-11011 December 2008 License Amendment Request Supplemental Regarding Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers and Relocate TS 3.7.8 to the TRM 2CAN070801, Supplement to License Amendment Request Regarding Technical Specification Changes Associated with Adoption of TSTF-3592008-07-0808 July 2008 Supplement to License Amendment Request Regarding Technical Specification Changes Associated with Adoption of TSTF-359 2CAN030806, Supplemental to License Amendment Request, Technical Specification 3.1.1.4, Moderator Temperature Coefficient2008-03-27027 March 2008 Supplemental to License Amendment Request, Technical Specification 3.1.1.4, Moderator Temperature Coefficient 2CAN100701, License Amendment Request - Technical Specification Changes Regarding Mode Change Limitations and Associated Bases Using the Consolidated Line Item Improvement Process2007-10-22022 October 2007 License Amendment Request - Technical Specification Changes Regarding Mode Change Limitations and Associated Bases Using the Consolidated Line Item Improvement Process 1CAN100703, License Amendment Request - Technical Specification Changes and Analyses Relating to Use of Alternate Source Term2007-10-22022 October 2007 License Amendment Request - Technical Specification Changes and Analyses Relating to Use of Alternate Source Term 2CAN100703, Unit 2 License Amendment Request for Technical Specification Change Associated with Replacement of Containment Sump Buffer2007-10-0505 October 2007 Unit 2 License Amendment Request for Technical Specification Change Associated with Replacement of Containment Sump Buffer ML0726300862007-09-28028 September 2007 License and Technical Specification Pages - Amendment No. 273 Revisions to TS to Support Partial Re-Rack and Revised Loading Patterns in the Spent Fuel Pool 2024-04-04
[Table view] Category:Bases Change
MONTHYEAR2CAN112302, Submittal of Amendment 31 to Safety Analysis Report2023-11-16016 November 2023 Submittal of Amendment 31 to Safety Analysis Report ML23208A2112023-07-27027 July 2023 Entergy Operations Inc., Application to Revise Technical Specifications to Adopt TSTF-205, Revision of Channel Calibration, Channel Functional Test, and Related Definitions 1CAN032301, License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure2023-03-30030 March 2023 License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure 1CAN122201, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42022-12-22022 December 2022 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 1CAN102201, Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations2022-10-13013 October 2022 Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations 2CAN042201, Amendment 30 to the ANO Unit 2 Safety Analysis Report2022-04-27027 April 2022 Amendment 30 to the ANO Unit 2 Safety Analysis Report 1CAN102101, SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report2021-10-0606 October 2021 SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report ML21279A2312021-10-0606 October 2021 Application to Revise Technical Specifications to Adopt TSTF-554, Revise Reactor Coolant Leakage Requirements Using the Consolidated Line-Item Improvement 2CAN121901, License Amendment Request Technical Specification Deletions, Additions, and Relocations2019-12-16016 December 2019 License Amendment Request Technical Specification Deletions, Additions, and Relocations 1CAN061902, Supplemental Change Related to Revise Technical Specifications to Adopt TSTF-567, Add Containment Sump TS to Address GSI-191 Issues2019-06-18018 June 2019 Supplemental Change Related to Revise Technical Specifications to Adopt TSTF-567, Add Containment Sump TS to Address GSI-191 Issues 1CAN031901, License Amendment Request Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an Lco.2019-03-25025 March 2019 License Amendment Request Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an Lco. 1CAN111802, ANO Unit 1 SAR Amendment 28, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report2018-11-12012 November 2018 ANO Unit 1 SAR Amendment 28, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report 2CAN111702, License Amendment Request - Updating the Reactor Coolant System Pressure-Temperature Limits2017-11-20020 November 2017 License Amendment Request - Updating the Reactor Coolant System Pressure-Temperature Limits 1CAN031604, Arkansas, Unit 1 - Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Co2016-03-25025 March 2016 Arkansas, Unit 1 - Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Code 2CAN031602, Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the Asme..2016-03-25025 March 2016 Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the Asme.. 2CAN121502, Application to Revise Technical Specifications to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c, Using the Consolidated Line Item Improvement Process2015-12-22022 December 2015 Application to Revise Technical Specifications to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c, Using the Consolidated Line Item Improvement Process 1CAN121403, License Amendment Request Supplemental ANO-1 Adoption of TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441).2014-12-0505 December 2014 License Amendment Request Supplemental ANO-1 Adoption of TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441). 1CAN011406, Amendment 25 of the ANO Unit 1 Safety Analysis Report2014-01-29029 January 2014 Amendment 25 of the ANO Unit 1 Safety Analysis Report 2CAN061302, License Amendment Request - Supplemental Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-4712013-06-18018 June 2013 License Amendment Request - Supplemental Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 1CAN031306, License Amendment Request, Adoption of Technical Specification Task Force (TSTF)-431, Revision 3 Change in Technical Specifications End States (BAW-2441)2013-03-26026 March 2013 License Amendment Request, Adoption of Technical Specification Task Force (TSTF)-431, Revision 3 Change in Technical Specifications End States (BAW-2441) 1CAN041102, License Amendment Request, Adoption of Technical Specification Task Force (TSTF)513, Revision 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation.2011-04-29029 April 2011 License Amendment Request, Adoption of Technical Specification Task Force (TSTF)513, Revision 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation. 1CAN081001, License Amendment Request, Technical Specification Change Associated with Main Feedwater Isolation Valves2010-08-24024 August 2010 License Amendment Request, Technical Specification Change Associated with Main Feedwater Isolation Valves 2CAN081009, Emergency License Amendment Request Extension of ANO-2 Emergency Diesel Generator Allowed Outage Time2010-08-19019 August 2010 Emergency License Amendment Request Extension of ANO-2 Emergency Diesel Generator Allowed Outage Time 1CAN081002, License Amendment Request, Changes to Technical Specification 3.9.3, Technical Change Traveler - TSTF-312, Rev. 12010-08-10010 August 2010 License Amendment Request, Changes to Technical Specification 3.9.3, Technical Change Traveler - TSTF-312, Rev. 1 1CAN021004, Response to Request for Additional Information, Application for Technical Specification Improvement to Adopt TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec.2010-02-28028 February 2010 Response to Request for Additional Information, Application for Technical Specification Improvement to Adopt TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec. 2CAN060903, License Amendment Request, Technical Specification Changes to Relocate Pressurizer Heater Requirements to Technical Requirements Manual2009-06-18018 June 2009 License Amendment Request, Technical Specification Changes to Relocate Pressurizer Heater Requirements to Technical Requirements Manual 1CAN030901, License Amendment Request on Technical Specification Change to Delete Low Pressurizer Level Limit2009-03-10010 March 2009 License Amendment Request on Technical Specification Change to Delete Low Pressurizer Level Limit 2CAN030902, License Amendment Request, Technical Specification Change to Delete COLR References2009-03-10010 March 2009 License Amendment Request, Technical Specification Change to Delete COLR References 2CAN120801, License Amendment Request Supplemental Regarding Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers and Relocate TS 3.7.8 to the TRM2008-12-11011 December 2008 License Amendment Request Supplemental Regarding Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers and Relocate TS 3.7.8 to the TRM 2CAN070801, Supplement to License Amendment Request Regarding Technical Specification Changes Associated with Adoption of TSTF-3592008-07-0808 July 2008 Supplement to License Amendment Request Regarding Technical Specification Changes Associated with Adoption of TSTF-359 1CAN100703, License Amendment Request - Technical Specification Changes and Analyses Relating to Use of Alternate Source Term2007-10-22022 October 2007 License Amendment Request - Technical Specification Changes and Analyses Relating to Use of Alternate Source Term ML0722901082007-08-0202 August 2007 Supplement to Amendment Request to Delete the Fuel Handling Area Ventilation System and Associated Filter Testing Program Requirements 2CAN030701, Arkansas One, Unit 2, License Amendment Request, Proposed Technical Change Regarding Containment Spray Nozzle Test Requirements2007-03-15015 March 2007 Arkansas One, Unit 2, License Amendment Request, Proposed Technical Change Regarding Containment Spray Nozzle Test Requirements ML0600504482006-01-0303 January 2006 Arkansas Nuclear One - Unit 1, License Amendment Request - Request for Emergency Technical Specification Change to Revise the Actuation Allowable Value for Emergency Feedwater Initiation and Control Function ML0619401702005-09-19019 September 2005 Arkansas Unit 2, Technical Specifications, Channell Functional Test 2CAN010505, Arkansas, Unit 2 - 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2CAN120801
December 11, 2008
U.S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
SUBJECT:
License Amendment Request Supplemental Regarding Technical Specification Change to Add LCO 3.0.8 on
the Inoperability of Snubbers and Relocate TS 3.7.8 to the TRM
Arkansas Nuclear One, Unit 2
Docket No. 50-368
License No. NFP-6
REFERENCE:
- 1. Entergy letter to NRC dated July 21, 2008, License Amendment Request Regarding Technical Specification Change to Add LCO 3.0.8
on the Inoperability of Snubbers and Relocate TS 3.7.8 to the TRM, TAC No. MD9483 (2CAN070805)
Dear Sir or Madam:
In accordance with the provisions of 10 CFR 50.90, Entergy Operations, Inc. (Entergy)
submitted a request for an amendment (Reference 1) to the Technical Specifications (TS) for
Arkansas Nuclear One, Unit 2 (ANO-2).
The proposed amendment would modify TS r equirements for inoperable snubbers by adding a Limiting Condition for Operation (LCO) 3.0.8 and relocating the current TS 3.7.8, Shock
Suppressors (Snubbers), to the Technical Requirements Manual (TRM).
The NRC notified Entergy on November 24, 2008, that additional information was required
relating to station procedures and controls that would ensure the opposite train Emergency
Feedwater (EFW) system would be verified operabl e prior to removing snubbers from service on a given system. Entergy's response to the NRC's request for additional information (RAI)
is included in Attachment 1 of this submittal.
The additional information provided in Attachment 1 does not invalidate the original No
Significant Hazards Considerations of the original ANO-2 TS change request (Reference 1).
This letter contains no new commitments.
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802
Tel 479-858-3110 Timothy G. Mitchell Vice President, Operations A rkansas Nuclear One
2CAN120801 Page 2 of 2
If you have any questions or require additional information, please contact Dale James at 479-858-4619.
I declare under penalty of perjury under the laws of the United States of America that I am
authorized by Entergy to make this request and that the foregoing is true and correct.
Executed on December 11, 2008.
Sincerely, TGM/dbb
Attachment:
- 1. Response to Request for Additional Information Regarding Adoption of LCO 3.0.8 (Snubbers) 2. Revised Markup of Affected Technical Specification Bases Pages (Information Only)
cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-8064
NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310
London, AR 72847
U. S. Nuclear Regulatory Commission
Attn: Mr. Alan B. Wang
MS O-7 D1
Washington, DC 20555-0001
Mr. Bernard R. Bevill
Director Division of Radiation
Control and Emergency Management
Arkansas Department of Health & Human Services P.O. Box 1437 Slot H-30 Little Rock, AR 72203-1437
Attachment 1 To 2CAN120801 Response to Request for Additional Information Regarding Adoption of LCO 3.0.8 (Snubbers) to 2CAN120801
Page 1 of 4
Response to Request for Additional Information Regarding Adoption of LCO 3.0.8 (Snubbers)
On July 21, 2008, Entergy Operations, Inc. (Entergy) submitted an amendment that would modify Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specification (TS) requirements for inoperable snubbers by relocating current snubber requirements in TS 3.7.8 to the Technical
Requirements Manual (TRM) and adding Limiting Condition for Operation (LCO) 3.0.8 to the
TSs.
The NRC notified Entergy on November 24, 2008, that additional information was required
relating to station procedures and controls that would ensure the opposite train Emergency
Feedwater (EFW) system would be verified operabl e prior to removing snubbers from service on a given system. Entergy's response to the NRC's request for additional information (RAI) is
included below.
RAI Consistent with the staff's approval and inherent in the implementation of TSTF-372
Revision 4, licensees interested in implementing LCO 3.0.8 must, as applicable, operate in
accordance with stipulations. Section 3.0, Regulatory Analysis, Subsection 3.2, Verification
and Commitments, discusses the two Conditions for application of TSTF-372 specified in the
model Safety Evaluation.
Condition 1
Appropriate plant procedures and administrativ e controls will be used to implement the following Tier 2 Restrictions. Tier 2 restrictions (Conditions) involve the identification of
potentially high-risk configurations that could exist if equipment in addition to that associated
with the change were to be taken out of service simultaneously, or other risk significant
operational factors such as concurrent equipment testing were also involved.
(a) At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), must be available
when LCO 3.0.8a is used at PWR plants.
(b) At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), or some alternative
means of core cooling (e.g., F&B, fire water system or "aggressive secondary cooldown"
using the steam generators) must be available when LCO 3.0.8b is used at PWR plants.
Regarding Condition 1.a Entergy wrote:
Condition 1(a) assumes the availability of one Emergency Feedwater (EFW) train during
application of LCO 3.0.8.a. The TSTF-372 and the model SE specify the application of
LCO 3.0.8.a is contingent on the assumption that the redundant train remains available. Even
though ANO-1 has a unique EFW system design, the plant TS LCO and ACTION statements
will ensure the system remains capable of performing its safety function with various
combinations of pumps and flow paths OPERABLE. Although the TS implementation process to 2CAN120801
Page 2 of 4
at ANO-1 may include this restriction in other procedures or administrative processes upon approval of this amendment, Entergy does not believe further action is required to ensure
compliance with Condition 1(a) since the TS inherently prevents application of LCO 3.0.8.a
due to a snubber-related condition which could render the entire EFW system inoperable.
Regarding Condition 1.b, Entergy wrote:
Condition 1(b) requires either one EFW train or some alternative means of core cooling must
be available when one or more snubbers are inoperable that affect both trains of a given
system. As described in Condition 1(a) above, there are no instances where the EFW system or both trains of any system being relied upon as the only core cooling method would be
removed from service or any work permitting both at the same time during its associated
Modes of Applicability that require these systems. Again, such a plant configuration would
result in LCO 3.0.3 entry or plant shutdown, which prevents the utilization of the 12-hour
allowance of LCO 3.0.8.b. Although the TS implementation process at may include this
restriction in other procedure or administrat ive processes upon approval of this amendment.
Entergy believes the TS LCO and ACTION statements will ensure the system remains capable
of performing its safety function with no further action required to ensure compliance with
Condition 1 (b).
It is not clear to the staff what these statement s mean in terms of taking actions to implement Tier 2 restrictions. Conclusions made by the licensee that would result in exceptions to or
deviations from TSTF-372 model SE requirements to establish plant procedures and
administrative controls to implement Tier 2 Restrictions need to include an analysis basis for
the conclusion. The license application regulatory analysis needs to address this issue for
condition 1(a) and 1(b) conclusions.
REGULATORY ANALYSIS BASIS FOR RAI
Regulations
10 CFR 50.36(d)(2)(i),states:
Limiting conditions for operation. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. 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.
LCO 3.0.8 modifies TS requirements on the impact of inoperable snubbers. Under LCO 3.0.8
TS systems would remain operable when requir ed snubbers are not capable of providing their related support function. The licensee stated that the proposed amendment is consistent with
staff approved TSTF-372, Rev 4, "Addition of LCO 3.0.8, Inoperability of Snubbers."
TSTF-372, Revision 4, documents a risk-informed analysis of the proposed TS change. The
risk assessment associated with the proposed delay times for entering the TS actions for the
supported equipment was performed following the three-tiered approach recommended in
RG 1.177 for evaluating proposed extensions in currently allowed CTs: to 2CAN120801
Page 3 of 4
The second tier involves the identification of potentially high-risk configurations that could exist if equipment in addition to that associated with the change were to be taken out of service
simultaneously, or other risk-significant operational factors such as concurrent equipment
testing were also involved. The objective is to ensure that appropriate restrictions are in place
to avoid any potential high-risk configurations.
Entergy Response As discussed in the July 21, 2008, Entergy letter, adoption of LCO 3.0.8 requires the
availability of EFW (or other core cooling method in lower modes of operation) during periods
when one or more required snubbers are inoperable. While the TSs ensure an EFW train or
other core cooling method is operable in accordance with the related mode of applicability, the
TSs do not address which train (of a two-train system) must be operable. The NRC Safety
Evaluation (SE) for adoption of TSTF-372 clearly indicates that the train of EFW or core
cooling redundant to the system train in which a snubber is removed from service or otherwise declared inoperable must be operable in order to apply the provisions of LCO 3.0.8.
In order to ensure redundant train operability of EFW or other core cooling method relied upon, Entergy maintains several tiers of procedures and controls that prevent intrusive activities from
being performed on redundant trains of equipment. Corporate procedures that govern all
Entergy sites only permit work to be scheduled on one train at a time and that the aggregate
risk be assessed prior to removing various safety-related components from service on a given
train simultaneously. For example, if the red-train Emergency Diesel Generator (EDG) were removed from service, no intrusive activiti es would be permitted on or around any required green-train component, whether or not the component is related to the EDG. This
administrative control even prohibits activities t hat could in any way affect the availability or operability of the redundant train, including activities such as scaffold erection. With the red-
train EDG removed from service, other red-train components may be removed from service simultaneously, provide the aggregate station risk is maintained within acceptable limits.
In addition to Corporate upper-tier procedures, each station maintains lower-tier procedures to
provide additional checks and balances to ensure redundant equipment is adequately
protected during any maintenance window. If during a red-train maintenance window a green-
train component is unexpectedly found to be inoperable, procedures require immediate
corrective action to restore both trains to an operable status. Risk is also assessed for such
emergent conditions and appropriate compensatory measures, which could include a plant
shutdown, are established as warranted to reduce overall station risk.
In summary, Entergy nuclear facilities have well established controls with regard to redundant
train operability which have long been a part of the Entergy culture. These controls provide
ample assurance that the intent of the NRC SE requirement for ensuring the availability and
operability of a redundant EFW or core cooling system train will be maintained during snubber
inoperability periods. In this respect, Entergy believes no deviation from the TSTF is evident.
Notwithstanding the above, there are certain aspects of the aforementioned Condition 1(a) that
must be addressed. Condition 1(a) does not address lower modes of operation when EFW is
not required to be operable or Steam Generators (SGs) are otherwise unavailable. Therefore, Entergy requests deviation from TSTF-372 such that when EFW is not required to be operable
by TSs, the redundant train core cooling source being relied upon during these lower modes of to 2CAN120801
Page 4 of 4
operation will be consider sufficient to meet the intent of the TSTF-372 SE. This condition was identified to the NRC following TSTF-372 approval and a revision is currently being considered
by the industry TSTF working group. As discussed previously, Entergy procedures currently
protect redundant equipment during a given train's maintenance window. Therefore, no
further administrative controls are required.
However, the TS Bases for LCO 3.0.8 as presented in TSTF-372 and the July 12, 2008, Entergy submittal does not describe the redundant EFW or core cooling source requirements.
Entergy believes it is appropriate to include these restrictions in the TS Bases. In addition to
providing discussion relevant to Condition 1(a) above, discussion is also included to provide guidance associated with Condition 1(b). This is necessary since ANO-2 is a two-train facility
and no redundant EFW train would exist for a snubber that affects both trains of a given system. The affected TS Bases pages hav e been modified to provide discussion and guidance for various modes of operation. A revised markup of the associated TS Bases
pages is included in Attachment 2 and the added guidance is included below:
"When applying LCO 3.0.8.a, the redundant train Emergency Feedwater (EFW)
system must be OPERABLE during MODES when EFW is required to be
OPERABLE. When applying LCO 3.0.8.a during MODES when EFW is not required
to be OPERABLE, the redundant core cooling method (such as Shutdown Cooling (SDC) system) must be available. When applying LCO 3.0.8.b, a means of core
cooling must remain available (EFW, SDC, equipment necessary for feed and bleed
operations, etc.). Reliance on availability of a core cooling source during modes
where EFW is not required by TSs provides an equivalent safety margin for plant
operations were LCO 3.0.8 not applied and meets the intent of Technical
Specification Task Force (TSTF) 372."
Reliance on the redundant train core cooling source during modes where EFW is not required
by TSs provides an equivalent safety margin and meets the intent of the NRC SE conditions.
Therefore, Entergy believes this deviation (or additional guidance) is acceptable.
Attachment 2 To 2CAN120801 Revised Markup of Affected Technical Specification Bases Pages (Information Only)
ARKANSAS - UNIT 2 B 3/4 0-1 e Rev. APPLICABILITY BASES (continued) 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36, and, as such, are appropriate for control by the licensee.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the ACTIONS entered in accordance with LCO 3.0.2.
LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system.
LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72-hour allowed outage time (AOT) is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.
LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12-hour AOT is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.
When applying LCO 3.0.8.a, the redundant train Emergency Feedwater (EFW) system must be OPERABLE during MODES when EFW is required to be OPERABLE. When applying LCO 3.0.8.a during MODES when EFW is not required to be OPERABLE, the redundant core cooling method (such as Shutdown Cooling (SDC) system) must be available. When applying LCO 3.0.8.b, a means of core cooling must remain available (EFW, SDC, equipment necessary for feed and bleed operations, etc.). Reliance on availability of a core cooling source during modes where EFW is not required by TSs provides an equivalent safety margin for plant operations were LCO 3.0.8 not applied and meets the intent of Technical Specification Task Force (TSTF) 372.
ARKANSAS - UNIT 2 B 3/4 0-1 f Rev. APPLICABILITY BASES (continued) 3.0.8 (continued)
LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues ar e properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.
LCO 3.0.8 does not apply to non-seismic snubbers. The provisions of LCO 3.0.8 are not to be applied to supported TS systems unl ess the supported systems would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.
The risk impact of dynamic loadings other than seismic loads was not assessed as part of the development of LCO 3.0.8. These shock-type loads include thrust loads, blowdown loads, water-hammer loads, steam-hammer loads, LOCA loads and pipe rupture loads. However, there are some important distinctions between non-seismic (shock-type) loads and seismic loads which indicate that, in general, the risk impact of the out-of-service snubbers is smaller for non-seismic loads than for seismic loads.
First, while a seismic load affects the entire plant, the impact of a non-seismic load is localized to a certain system or area of the plant. Second, although non-seismic shock loads may be higher in total force and the impact could be as much or more than seismic loads, generally they are of much shorter duration than seismic loads. Third, the impact of non-seismic loads is more plant specific, and thus harder to analyze generically, than for seismic loads. For these reasons, every time LCO 3.0.8 is applied, at least one train of each system that is supported by the inoperable snubber(s) should remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.