0CAN081407, Response to Request for Additional Information Adoption of Technical Specification Task Force TSTF-431, Revision 3 and Adoption of TSTF-422, Revision 2 Regarding Technical Specifications End States

Response to Request for Additional Information Adoption of Technical Specification Task Force TSTF-431, Revision 3 and Adoption of TSTF-422, Revision 2 Regarding Technical Specifications End States

ML14231A370
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/19/2014
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN081407
Download: ML14231A370 (8)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Site Vice President Arkansas Nuclear One 0CAN081407 August 19, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Request for Additional Information Adoption of Technical Specification Task Force (TSTF)-431, Revision 3 (ANO-1), and Adoption of TSTF-422, Revision 2 (ANO-2) Regarding Technical Specifications End States Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

Dear Sir or Madam:

By letter dated August 4, 2014 (Reference 3), the NRC requested additional information associated with the Entergy Operations, Inc. (Entergy) request to amend the Arkansas Nuclear One, Unit 1 (ANO-1) and Unit 2 (ANO-2) Technical Specifications (TS) to incorporate the NRC approved TSTF-431, Revision 3, and TSTF-422, Revision 2, regarding a change in TS end states. The proposed amendment would modify TSs to risk-inform requirements regarding selected Required Action end states.

During the license amendment request (LAR) review, the NRC staff noted that one of the regulatory guidance documents used in the staffs regulatory assessment for the TSTFs, and referenced in the staffs associated model safety evaluations (SEs), has since been superseded. The issue concerns a specific reference to Regulatory Guide (RG) 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants, contained in both TSTF-431 and TSTF-422. RG 1.182 was withdrawn since it was determined that the document was redundant due to the inclusion of its subject matter in Revision 3 of RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The withdrawal notice for RG 1.182 was published in the Federal Register on November 27, 2012 (78 FR 70846).

In addition, the NRC staff observed that RG 1.160 endorsed Revision 4A of the Nuclear Management and Resources Council (NUMARC) 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. NUMARC 93-01 provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The model SEs for the TSTFs currently refer to the guidance in Revision 2 of the NUMARC 93-01.

0CAN081407 Page 2 of 4 In order to justify adoption of the TSTF changes, the NRC has requested (Reference 3) confirmation that ANO-1 and ANO-2, adhere to the RG 1.160 guidance, including the updated version of NUMARC 93-01. The response should confirm that the topical reports supporting the LARs comply with NUMARC 93-01, Section 11, and identify, if any, inconsistencies with this section.

Entergys confirmation of the subject matter follows.

Entergy committed ANO-1 and ANO-2 to follow the guidance established in TSTF-IG-07-01, Revision 1, Implementation Guidance for TSTF-431, Revision 3, Change in Technical Specifications End States, BAW-2441-A," and WCAP-16364-NP, Revision 2, Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422), respectively, as part of the original LARs (References 1 and 2). Both guidance documents require plants adopting the end states TSTFs to commit to the guidance contained in Section 11 of NUMARC 93-01, Revision 3, for assessing risk associated with maintenance activities. RG 1.182 is referenced in both guidance documents only to state that RG 1.182 endorses NUMARC 93-01 as one acceptable approach to implement 10 CFR 50.65(a)(4), but is not otherwise mentioned.

Topical Report BAW-2441, Risked Informed Justification for LCO End State Changes, and the associated NRC SE do not reference RG 1.160, RG 1.182, or NUMARC 93-01, but do require a program be established to address 10 CFR 50.65(a)(4) Maintenance Rule aspects with respect to risk management. Similar to the aforementioned guidance for Combustion Engineering (CE) plants, Topical Report CENSPD-1186, Technical Justification for the Risk Informed Modification to Selected Required Action End States for CEOG Member PWRs, and its associated NRC SE, references RG 1.182 with regard to its endorsement of NUMAR 93-01.

Both Revisions 2 and 3 of the NUMARC are mentioned in the CE report. NUMARC 93-01, Revision 4A, incorporated additional guidance related to fire risk, equipment to be scoped in the Maintenance Rule, and the definition of availability was modified. The guidance included in RG 1.160, Revision 3, and NUMARC 93-01, Revision 4A, built upon and/or enhanced that provided in RG 1.182 or in previous revisions to the NUMARC; therefore, application of RG 1.160, Revision 3, and NUMARC 93-01, Revision 4A, does not result in inconsistencies with the intent of the topical reports, supporting topical report SEs, or the aforementioned TSTF end state implementation guidance.

Entergy fleet procedure EN-DC-203, Maintenance Rule Program, currently references NUMARC 93-01 and RG 1.160 as the base guidance documents for implementation of the Maintenance Rule at Entergy sites, which includes ANO-1 and ANO-2. Furthermore, the industry committed (Reference 4) through the Nuclear Energy Institute (NEI) to implement RG 1.160, Revision 3, which endorses NUMARC 93-01, Revision 4A. As a result, Entergy fleet procedure EN-OU-108, Shutdown Safety Management Program (SSMP), was revised with reference to NUMAR 93-01 to include qualitative risk guidance and risk management actions (RMAs), such as those applicable to fire-related features which become unavailable during shutdown operational modes. ANO procedure COPD-024, Risk Assessment Guidelines, was also revised to include comprehensive guidance related to fire risks and RMAs, and specifically discusses the guidance contained in NUMARC 93-01, Revision 4A.

The ANO end state LARs committed to Section 11 of NUMARC 93-01, Revision 3, with regard to assessing risk in support of the new Mode 4 end states delineated in the subject TSTFs. As stated previously, the ANO LARs also committed to the respective implementation guidance documents, which refer to Revision 3 of the NUMARC. Although the ANO Maintenance Rule

0CAN081407 Page 3 of 4 program is currently based on NUMAR 93-01, Revision 4A, the aforementioned commitments are updated to reflect the intended guidance. Attachments 1 and 2 of this letter provide an updated list of regulatory commitments associated with the ANO-1 and ANO-2 end state LARs (References 1 and 2), respectively. The complete table listing of commitments is included from each original LAR for completeness. These two attachments supersede Attachment 2 of the Reference 1 and 2 LARs, respectively.

Additional information, as detailed in this letter, with respect to the original Entergy requests (References 1 and 2) has been reviewed and Entergy has determined that the information does not invalidate the no significant hazards consideration discussed in the Reference 1 and 2 letters.

In accordance with 10 CFR 50.91(b)(1), a copy of this response is being provided to the designated Arkansas state official.

Revised commitments are included in Attachments 1 and 2 of this letter.

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

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

Executed on August 19, 2014.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWING JGB/dbb Attachments:

1. Revised List of Regulatory Commitments - ANO-1 End States

2. Revised List of Regulatory Commitments - ANO-2 End States

0CAN081407 Page 4 of 4

REFERENCES:

1. Entergy letter dated March 26, 2013, License Amendment Request -

Adoption of Technical Specification Task Force (TSTF)-431, Revision 3, "Change in Technical Specifications End States (BAW-2441)"

(1CAN031306) (ML13085A282)

2. Entergy letter dated March 26, 2013, License Amendment Request -

Adoption of Technical Specification Task Force (TSTF)-422, Revision 2, Change in Technical Specifications End States (CE NPSD-1186)

(2CAN031303) (ML13085A283)

3. NRC letter dated August 4, 2014, Request for Additional Information Regarding License Amendment Requests to Adopt Changes to Technical Specification End States (0CNA081401) (ML14209A627)

4. NEI letter dated January 4, 2011, Revision 4 to NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants (ML110280083) cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Ms. Andrea E. George MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Attachment 1 to 0CAN081407 Revised List of Regulatory Commitments - ANO-1 End States to 1CAN031306 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMMITMENT COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE Entergy will modify the Technical Upon Specification Bases for the revised implementation of specifications as adopted with the the approved TS applicable license amendment. amendment Entergy will follow the guidance established in Section 11 of NUMARC 93-01, Industry Guidance for Monitoring the Effectiveness Ongoing of Maintenance at Nuclear Power Plants, Nuclear Management and Resource Council, Revision 4A, April 2011.

Entergy will follow the guidance established Upon in TSTF-IG-07-01, Revision 1, implementation of Implementation Guidance for TSTF-431, the approved TS Revision 3, Change in Technical amendment, Specifications End States, BAW-2441-A, , when the TS with the exception that Section 11 of Required Action NUMARC 93-01, Revision 4A, will be End State utilized to meet 10 CFR 50.65(a)(4) remains within requirements in lieu of NUMARC 93-01, the Applicability Revision 3. of the TS

Attachment 2 to 0CAN081407 Revised List of Regulatory Commitments - ANO-2 End States to 2CAN031303 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMMITMENT COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE Entergy will modify the Technical Upon Specification Bases for the revised implementation of specifications as adopted with the the approved TS applicable license amendment. amendment Entergy will follow the guidance established in Section 11 of NUMARC 93-01, Industry Guidance for Monitoring the Effectiveness Ongoing of Maintenance at Nuclear Power Plants, Nuclear Management and Resource Council, Revision 4A, April 2011.

Entergy will follow the guidance established Upon in WCAP-16364-NP, Revision 2, implementation of Implementation Guidance for Risk the approved TS Informed Modification to Selected Required amendment, Action End States at Combustion when the TS Engineering NSSS Plants (TSTF-422),

Required Action dated May 2010, with the exception that End State Section 11 of NUMARC 93-01, remains within Revision 4A, will be utilized to meet the Applicability 10 CFR 50.65(a)(4) requirements in lieu of of the TS NUMARC 93-01, Revision 3.