LIC-08-0008, License Amendment Request (LAR) Revision to Technical Specification (TS) 2.5(1)A, Auxiliary Feedwater (AFW) System.

License Amendment Request (LAR) Revision to Technical Specification (TS) 2.5(1)A, Auxiliary Feedwater (AFW) System.

ML080360537
Person / Time
Site:	Fort Calhoun
Issue date:	02/05/2008
From:	Bannister D Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-08-0008
Download: ML080360537 (15)

Text

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iiiijiiJ Omaha Public Power District 444 South 16th Street Mall Omaha NE 68102-2247 February 5,2008 LIC-08-0008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. NRC Letter to the Technical Specification Task Force, Status of TSTF 439, Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet An LCD, dated January 11, 2006 (ML060120272)

SUBJECT:

Fort Calhoun Station, Unit No.1, License Amendment Request (LAR) "Revision to Technical Specification (TS) 2.5(1 )A, Auxiliary Feedwater (AFW) System" Pursuant to 10 CFR 50.90, the Omaha Public Power District (OPPD) hereby requests an amendment to Fort Calhoun Station (FCS), Unit No.1, Renewed Facility Operating License No. DPR-40. The enclosed license amendment request (LAR) proposes to eliminate the second completion time from TS 2.5(1 )A, which pertains to the AFW system.

A second completion time was included in TS 2.5(1)A for certain conditions/required actions to establish a limit on the maximum time allowed for any combination of conditions that result in a single contiguous failure to meet the Limiting Condition for Operation (LCD). This LAR is consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Traveler number TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCD, dated June 20, 2005. In Reference 2, the NRC accepted TSTF-439 and incorporated the changes into Revision 3.1 of the Standard Technical Specifications.

The enclosure contains a description of the proposed changes, the supporting technical analyses, and the no significant hazards consideration determination. Attachment 1 provides the existing TS and Bases pages marked-up to show the proposed changes.

Attachment 2 provides the retyped (clean) TS and Bases pages. The TS Bases change is provided for information only and will be incorporated in the FCS TS pursuant to TS Employment with Equal Opportunity

u. S. Nuclear Regulatory Commission Lle-08-0008 Page 2 5.20, Technical Specifications (TS) Bases Control Program, when the amendment is implemented.

OPPD has determined that this LAR does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

There are no new regulatory commitments associated with this proposed change.

OPPD requests approval by September 1, 2008 with a gO-day implementation period.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Nebraska Official.

If you should have any questions regarding this submittal, please contact Mr. Thomas C. Matthews at (402) 533-6938.

I declare under penalty of perjury that the foregoing is true and correct. (Executed on February 5,2008.)

DJB/MLE/mle Enclosure OPPD's Evaluation of the Proposed Changes c: Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and l-Iuman Services, State of Nebraska

LIC-08-0008 Enclosure Page 1 Omaha Public Power District's Evaluation for Amendment of Operating License "Revision to Technical Specification (15) 2.5(1 )A, Auxiliary Feedwater (AFW) System" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

ATTACHMENTS:

1. Technical Specification & Bases Pages (Mark-ups of Proposed Changes)

2. Proposed Technical Specifications & Bases Pages (Clean)

LIC-OB-OOOB Enclosure Page 2

1.

SUMMARY

DESCRIPTION The Omaha Public Power District hereby requests an amendment to Fort Calhoun Station (FCS), Unit No.1, Renewed Facility Operating License No. DPR-40 by incorporating the attached change into the FCS Technical Specifications (TS). The proposed change would revise the Operating License to delete the second completion time from TS 2.5(1)A and is consistent with Technical Specification Task Force (TSTF)

Traveler TSTF-439, Revision 2, Eliminate Second Completion Time From Discovery of Failure to Meet an LCO (Reference 6.1). The NRC approved TSTF-439, Revision 2 on January 11 , 2006 (Reference 6.2).

2. DETAILED DESCRIPTION A second completion time is included to establish a limit on the maximum time allowed for any combination of conditions that result in a single contiguous failure to meet the Limiting Condition for Operation (LCO). This completion time (henceforth referred to as "second completion time n ) is joined to the condition specific completion time of TS 2.5(1)A (restore the steam supply to OPERABLE status within 7 days), and states and within 8 days from discovery of failure to meet the LCD. The second completion time is being deleted from TS 2.5(1 )A.

A proposed revision to the Bases of TS 2.5 is included in this application and is provided for information only. The TS Bases change will be incorporated in accordance with TS 5.20, Technical Specification (TS) Bases Control Program when the amendment is implemented.

3. TECHNICAL EVALUATION Between July and December of 1991, the NRC and the Improved Standard Technical Specification (ISTS) lead plants discussed an issue affecting a small number of TS that could theoretically allow indefinite operation of the plant while not meeting a LCO.

If an LCO requires OPERABILITY of two systems, it is possible to enter the condition for one inoperable system and before restoring the first system, the second system becomes inoperable. With the second system inoperable, the first system is restored to OPERABLE status. Before restoring the second system, the first system becomes inoperable again, and so on. Under this scenario, it would be theoretically possible to operate indefinitely without ever meeting the LCO. This also could occur with LeOs that require only one system to be OPERABLE, but for which the conditions describe two or more mutually exclusive causes of inoperability.

It is important to note that this issue of alternating between conditions only applies if the LCO is not met. If the LCO requirements are met, even for an instant, this issue does not occur. This is a highly unlikely scenario and the Industry argued that it would never

LIC-D8-00G8 Enclosure Page 3 occur, but the NRC believed it should be addressed when developing the ISTS because there were no other regulatory processes in place at that time which could prevent or respond to such a situation, should it occur.

The addition of these second completion times did not originally create an operational restriction because the likelihood of experiencing concurrent failures such that the second completion time is limiting is very remote.

However, these second completion times became a problem when the Industry proposed risk-informed completion times for some of the specifications, which contained the second completion times in Industry/Technical Specification Task Force (TSTF)

Traveler number TSTF-409, Containment Spray System Completion Time Extension, and TSTF-430, AOT Extension to 7 Days for LPI and Containment Spray. These Travelers extended a completion time and, following the methodology described in the August 5, 1991 memo, the second completion time was extended by the same amount (Le., the second completion time continued to be the sum of the two completion times).

However, in letters to the TSTF dated November 15, 2001 and September 10, 2002, the NRC stated that the extension of the second completion time in TSTF-409 and TSTF 430 was inappropriate because one of the two completion times added to obtain the second completion time limit was risk based and the other was deterministic. On September 10, 2002, the NRC provided a letter making a similar statement regarding TSTF-430. Eventually, the NRC agreed that it was acceptable to add these two completion times and TSTF-409 and TSTF-430 were approved. However, second completion times complicate the presentation of the ISTS and complicate the implementation of risk-informed completion times. In addition, other regulatory requirements, not present when the ISTS NUREGs were originally developed, eliminate the need for these second completion times.

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 that provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second completion times were designed to prevent.

The Maintenance Rule: 10 CFR 50.65(a)(1), the Maintenance Rule, 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 Idoes not meet established goals, appropriate corrective action is required to be taken.

The NRC Resident Inspectors monitor the licensee's corrective action process and

LIC-08-00c8 Enclosure Page 4 could take action if the licensee's 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 LCO 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. 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 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. 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.

The 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 was endorsed by the NRC in Regulatory Issue Summary (RIS) 2001-11, Voluntary Submission Of Performance Indicator Data. NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses the auxiliary feedwater system. Extended unavailability of this system due to multiple entries into the LCO would affect the NRC's evaluation of the licensee's performance under the ROP.

FCS has custom TS and a second completion time is found only in the TS for the AFW system. Amendment 212 (Reference 6.1) added a second completion time to TS 2.5(1)A (AFW system) for consistency with ISTS. The TS 2.5(1) LCO requires two AFW trains to be OPERABLE when Tcol d is above 300°F. Condition A has a 7-day completion time for one inoperable steam supply to the turbine driven AFW pump and condition B

LIC-OB-OOOB Enclosure Page 5 has a 24-hour completion time for one AFW train inoperable for reasons other than condition A. Condition A has a second completion time of 8 days from discovery 0 failure to meet the LCO. The second completion time is not needed. The ROP monitors the availability of the AFW system. Frequent, repeated failures of the AFW system would be reported to the NRC, which represents a strong disincentive for such operation.

Based on the above discussion, the concern regarding multiple continuous entries into conditions without meeting the LCO is addressed by the system unavailability monitoring programs described above. Therefore, this potential concern is no longer an issue and the TS can be simplified by eliminating the second completion time with no detriment to plant safety.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 Technical Specifications. 10 CFR 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 revised action continues to meet the requirements of this regulation.

10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The overall objective of this 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 revised action continues to meet the requirements of this regulation.

4.2 Precedent As noted in Reference 6.3, the NRC approved TSTF 439 and incorporated it in Revision 3.1 of the ISTS. In December 2006, TXU Generation Company LP (TXU Power) submitted an LAR eliminating second completion times from the TS for Comanche Peak Steam Electric Station (CPSES) Units 1 and 2. In October 2007, AmerenUE submitted an LAR eliminating second completion times from the TS for the Callaway Plant. Other plants have also submitted LARs eliminating second completion times from their TS.

4.3 Significant Hazards Consideration The technical specifications (TS) for Fort Calhoun Station (FCS), Unit No. 1 are modified to delete the second completion time associated with TS 2.5(1 )A. The Bases associated with this required action will be revised in accordance with TS 5.20 to delete discussion of the second completion time when the amendment is implemented. The

Lle-08-0008 Enclosure Page 6 Omaha Public Power District (OPPD) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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 the second completion time from the technical specifications pertaining to the auxiliary feedwater (AFW) system. Completion times are not an initiator of 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 time. 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, and 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 accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly 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 accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods g!overning 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 accident from any accident previously evaluated.

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

Response: No.

LIC-OB-OOOB Enclosure Page 7 The proposed change deleting the second completion time from the technical specification pertaining to the AFW system does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change.

The proposed changes 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.

4.4 CONCLUSION

S 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Therefore, OPPD concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

5.0 ENVIRONMENTAL CONSIDERATION

OPPD has evaluated the proposed amendment and has determined that the proposed amendment does 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 amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0. REFERENCES 6.1 Letter from NRC (A. B. Wang) to OPPD (R. T. Ridenoure), Issuance of Amendment 212, Steam and Feedwater Systems (TAC No. MB5838) , dated November 26, 2002, NRC-02-0174, (ML022550475) 6.2 Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change TSTF-439, Revision 2, Eliminate Second Completion Time From Discovery of Failure To Meet an LCD, dated June 20,2005 6.3 Letter from NRC (T. H. Boyce) to the Technical Specification Task Force, Status of TSTF 439, Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet An LCD, dated January 11 , 2006 (ML060120272)

LIC-OB-OODa Page 1 Technical Specification & Bases Pages (Mark-ups of Proposed Changes)

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.5 Steam and Feedwater Systems Applicability When steam generators are relied upon for reactor coolant system heat removal.

NOTE: When heating the reactor coolant above 300°F the steam driven auxiliary feedwater (AFW) pump is only required to be OPERABLE prior to making the reactor critical.

Objective To define certain conditions for the steam and feedwater system necessary to assure adequate decay heat removal.

Specifications (1) Two AFW trains shall be OPERABLE when Tcold is above 300°F.

A. With one steam supply to the turbine driven AFW pump inoperable, restore the steam supply to OPERABLE status within 7 days and '.tt'ithin 8 days from disco'/ery of failure to meet the LCO.

B. With one AFW train inoperable for reasons other than condition A, restore the AFW train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c. If the required action and associated completion times of condition A or B are not met, then the unit shall be placed in MODE 2 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in MODE 3 in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and less than 30QoF without reliance on the steam generators for decay heat removal within the next 18 h,ours.

D. With both AFW trains inoperable, then initiate actions to restore one AFW train to OPERABLE status immediately. Technical Specification (TS) 2.0.1 and all TS actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

(2) The motor driven train is required to be OPERABLE when Tcold is below 30QoF and the steam generators are relied upon for heat removal. With the motor driven AFW train inoperable, then initiate actions to restore one AFW train to OPERABLE status immediately. Technical Specifications (TS) 2.0.1 and all TS actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

(3) A minimum of 55,000 gallons of water in the emergency feedwater storage tank (EFWST) and a backup water supply to the emergency feedwater storage tank shall be available. With the EFWST inoperable, verify operability of the backup water supply within four hours and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter, and restore the EFWST 2.5 - Page 1 Amendment No. 49,127,.:1-99,~

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.5 Steam and Feedwater Systems to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If these action requirements cannot be satisfied, then the unit shall be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and less than 30QoF without reliance on the steam generators for decay heat removal within the next 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

(4) The main steam stop valves are OPERABLE when Tco1d is above 300°F and capable of closing in four seconds or less under no-flow conditions.

Basis A reactor shutdown from power requires a removal of core decay heat. Immediate decay heat removal requirements are normally satisfied by the steam bypass to the condenser. Therefore, core decay heat can be continuously dissipated via the steam bypass to the condenser as long as feedwater to the steam generator is available. Normally, the capability to supply feedwater to the steam generators is provided by operation of the turbine cycle feedwater system. In the unlikely event of complete loss of electrical power to the station, decay heat removal is by steam discharge to the atmosphere via the main steam safety and atmospheric dump valves. Either auxiliary feed pump can supply sufficient feedwater for removal of decay heat from the plant. Technical Specification 2.1.1 establishes when the steam generators are required for heat removal. Each train includes the pump, piping, instruments, and controls to ensure the availability of an OPERABLE flow path capable of taking suction from the EFWST and delivering water to the steam generators. The eight day completion time for 2.5(1 ))A, provides a limit in the maximum time allov/ed for any combination to be inoperable during any continuous failure to meet the LCO. With one of the required AFW trains inoperable, actions must be taken to restore OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With no AFW trains OPERABLE the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting cooldown with nonsafety grade equipment. In such a condition the unit should not be perturbed by any action, including a power change, that might result in a trip.

The minimum amount of water in the emergency feedwater storage tank is the amount needed for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of such operation. The tank can be resupplied with water from the raw water system.(1)

A closure time of 4 seconds for the main steam stop valves is considered adequate time and was selected as being consistent with expected res:R0nse time for instrumentation as detailed in the steam line break analysis.( )(3)

References (1) USAR, Section 9.4.6 (2) USAR, Section 10.3 (3) USAR, Section 14.12 2.5 - Page 2 Amendment No. 2+,212

LIC-OB-OOOB Page 1 Proposed Technical Specifications & Bases Pages (Clean)

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.5 Steam and Feedwater Systems Applicability When steam generators are relied upon for reactor coolant system heat removal.

NOTE: When heating the reactor coolant above 300°F the steam driven auxiliary feedwater (AFW) pump is only required to be OPERABLE prior to making the reactor critical.

Objective To define certain conditions for the steam and feedwater system necessary to assure adequate decay heat removal.

Specifications (1) Two AFW trains shall be OPERABLE when Tcold is above 300°F.

A. With one steam supply to the turbine driven AFW pump inoperable, restore the steam supply to OPERABLE status within 7 days.

B. With one AFW train inoperable for reasons other than condition A, restore the AFW train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c. If the required action and associated completion times of condition A or B are not met, then the unit shall be placed in MODE 2 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in MODE 3 in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and less than 300°F without reliance on the steam generators for decay heat removal within the next 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

D. With both AFW trains inoperable, then initiate actions to restore one AFW train to OPERABLE status immediately. Technical Specification (TS) 2.0.1 and all TS actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

(2) The motor driven train is required to be OPERABLE when Tcold is b'elow 30QoF and the steam generators are relied upon for heat removal. With the motor driven AFW train inoperable, then initiate actions to restore one AFW train to OPERABLE status immediately. Technical Specifications (TS) 2.0.1 and all TS actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

(3) A minimum of 55,000 gallons of water in the emergency feedwater storage tank (EFWST) and a backup water supply to the emergency feedwater storage tank shall be available. With the EFWST inoperable, verify operability of the backup water supply within four hours and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter, and restore the EFWST 2.5 - Page 1 Amendment No. 4Q,127,4-99,~

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.5 Steam and Feedwater Systems to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If these action requirements cannot be satisfied, then the unit shall be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and less than 300°F without reliance on the steam generators for decay heat removal within the next 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

o (4) The main steam stop valves are OPERABLE when Teold is above 30Q F and capable of closing in four seconds or less under no-flow conditions.

Basis A reactor shutdown from power requires a removal of core decay heat. Immediate decay heat removal requirements are normally satisfied by the steam bypass to the condenser. Therefore, core decay heat can be continuously dissipated via the steam bypass to the condenser as long as feedwater to the steam generator is available. Normally, the capability to supply feedwater to the steam generators is provided by operation of the turbine cycle feedwater system. In the unlikely event of complete loss of electrical power to the station, decay heat removal is by steam discharge to the atmosphere via the main steam safety and atmospheric dump valves. Either auxiliary feed pump can supply sufficient feedwater for removal of decay heat from the plant. Technical Specification 2.1.1 establishes when the steam generators are required for heat removal. Each train includes the pump, piping, instruments, and controls to ensure the availability of an OPERABLE flow path capable of taking suction from the EFWST and delivering water to the steam generators. With one of the required AFW trains inoperable, actions must be taken to restore OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With no AFW trains OPERABLE the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting cooldown with nonsafety grade equipment. In such a condition the unit should not be perturbed by any action, including a power change, that might result in a trip.

The minimum amount of water in the emergency feedwater storage tank is the amount needed for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of such operation. The tank can be resupplied with water from the raw water system.(1)

A closure time of 4 seconds for the main steam stop valves is considered adequate time and was selected as being consistent with expected res:R0nse time for instrumentation as detailed in the steam line break analysis.( )(3)

References (1) USAR, Section 9.4.6 (2) USAR, Section 10.3 (3) USAR, Section 14.12 2.5 - Page 2