Text

License Amendment Request Regarding Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers
	ML082040887
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/21/2008
From:	Mitchell T; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	1CAN070803
	Download: ML082040887 (25)
	v • d • e

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Timothy G. Mitchell Vice President, Operations Arkansas Nuclear One 1CAN070803 July 21, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request Regarding Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90, Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the technical specifications (TS) for Arkansas Nuclear One, Unit 1 (ANO-1).

The proposed amendment would modify TS requirements for inoperable snubbers by adding LCO 3.0.8. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. provides a summary of the regulatory commitments made in this submittal. provides the existing TS Bases pages marked up to show the proposed change (for information only).

Entergy requests approval of the proposed License Amendment by February 1, 2009, with the amendment being implemented within 60 days.

If you have any questions or require additional information, please contact Dale James at 479-858-4619.

1CAN070803 Page 2 of 2 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 July 21, 2008.

Sincerely, TGM/dbb Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes

3. Revised Technical Specification Pages

4. Regulatory Commitments

5. Proposed Technical Specification Bases Changes (for 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 1CAN070803 Description and Assessment to 1CAN070803 Page 1 of 3

1.0 DESCRIPTION

The proposed amendment would modify Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specification (TS) requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8.

The changes relating to the addition of LCO 3.0.8 are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-372 Revision 4. The availability of this TS improvement was published in the Federal Register on April 27, 2005, as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Operations, Inc. (Entergy) has reviewed the safety evaluation dated April 27, 2005 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-372. Entergy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to ANO-1 and justify this amendment for the incorporation of the changes to the ANO-1 TS.

2.2 Optional Changes and Variations Item 1(e) of the model Safety Evaluation, Section 3.2, contains the statement LCO 3.0.8 does not apply to non-seismic snubbers. This does not appear to be captured in the implementation process of the TSTF. Therefore, Entergy proposes to include this statement in the LCO 3.0.8 Bases (see Attachment 5 of this submittal). Further guidance associated with the intent of this statement, as discussed in Section 3.0 of the model SE and in TSTF-IG-05-03, Implementation Guidance for TSTF-372, Revision 4, Addition of LCO 3.0.8, Inoperability of Snubbers, is also included in the Bases. In addition, the TSTF use of 10 CFR 50.36(c)(2)(ii) is modified to simply 10 CFR 50.36. This is due to the recent rule change that inadvertently re-designated Part 50.36(c) as Part 50.36(d).

The addition of LCO 3.0.8 resulted in an additional TS page being required and subsequent re-numbering of the pages that follow. This change is administrative in nature and has no bearing on the acceptability of the CLIIP adoption.

The above variations are few and insignificant with regard to ensuring proper application of TSTF-372 intent.

to 1CAN070803 Page 2 of 3

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Entergy Operations, Inc. (Entergy) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

Entergy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to ANO-1 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 27, 2005, for this TS improvement, plant-specific verifications were performed as follows.

In the model Safety Evaluation (SE), two requirements (the first of the two having five parts, 1(a) through 1(e)) for application of TSTF-372 are specified. Each is discussed below.

1. Item 1(a) assumes the availability of one Emergency Feedwater (EFW) train during application of LCO 3.0.8.a. TSTF-372, the model SE, and the LCO 3.0.8 TS Bases required to be adopted in conjunction with implementation of TSTF-372 all state the application of LCO 3.0.8.a is contingent on the assumption that the redundant train remains available. In addition, loss of both EFW trains during operation in the Modes of Applicability associated with EFW would result in LCO 3.0.3 entry, rendering the allowances of LCO 3.0.8 ineffective. Although the TS implementation process at ANO may include this restriction in other procedure or administrative processes upon approval of this amendment, Entergy does not believe further action is required to ensure compliance with Item 1(a) since the aforementioned documents inherently prevent application of LCO 3.0.8.a due to a snubber-related condition which could render both trains of any TS system inoperable and, LCO 3.0.3 entry would be required if both EFW trains were found to be inoperable during associated Modes of Applicability for any reason.

2. Item 1(b) requires either one EFW train or similar core cooling method to be available when one or more snubbers are inoperable that affect two trains of a given system. As described above, there are no instances where both EFW trains, or both trains of any system being relied upon as the only core cooling method would be removed from service during a Mode of Applicability that requires these systems. Again, such a plant configuration would result in LCO 3.0.3 entry, which prevents the utilization of the 12-hour allowance of LCO 3.0.8.b.

Although the TS implementation process at ANO may include this restriction in other procedure or administrative processes upon approval of this amendment, Entergy does not believe further action is required to ensure compliance with Item 1(b).

3. Items 1(c) and 1(d) are only applicable to west coast plants and boiling water reactors and, therefore, are not applicable to ANO-1.

to 1CAN070803 Page 3 of 3

4. The first portion of Item (1e) relates to Items 1(a) and 1(b), discussed above. The statement LCO 3.0.8 does not apply to non-seismic snubbers is added to the TS Bases (see markup in Attachment 5 of this submittal). This is a minor deviation from TSTF-372 and is discussed in Section 2.2 above. The remaining portion of Item 1(e) requires a record of the design function of the inoperable snubber (i.e., seismic vs. non-seismic) and implementation of any Tier 2 restrictions to be completed and available for staff inspection.

Entergy will ensure, during implementation of the LCO 3.0.8 snubber requirements, that the TRM Actions are modified, in accordance with 10 CFR 50.59, to require recognition of the design function of the inoperable snubber (i.e., seismic vs. non-seismic) and implementation of any Tier 2 restrictions each time a required snubber is rendered inoperable. This commitment is included in Attachment 4 of this submittal.

5. Item 2 discusses the availability and use of risk management. ANO-1 has and maintains a Continuous Risk Management Program (CRMP) and associated risk-related tools to meet the intent of 10 CFR 50.65(a)(4) of the Maintenance Rule. Entergy will revise station procedures or administrative process to ensure seismic risks are considered during application of the LCO 3.0.8 delay period when one or more snubbers are inoperable. This commitment is included in Attachment 4 of this submittal.

In addition to the above, Entergy will establish TS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements. This commitment is included in of this submittal. LCO 3.0.8 requires that risk be managed and assessed. The Bases also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, 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 are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. Finally, ANO-1 has a Bases Control Program consistent with Section 5.5 of the STS.

4.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model safety evaluation dated April 27, 2005, as part of the CLIIP. Entergy has concluded that the staffs findings presented in that evaluation are applicable to ANO-1 and the evaluation is hereby incorporated by reference for this application.

Attachment 2 To 1CAN070803 Proposed Technical Specification Changes

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, and LCO 3.0.7, and LCO 3.0.8.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or ANO-1 3.0-1 Amendment No. 215,232,

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 c. When an allowance is stated in the individual value, parameter, or (continued) other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCOs 3.1.8 and 3.1.9 allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

ANO-1 3.0-2 Amendment No. 215,232,

LCO Applicability 3.0 3.0 LCO APPLICABILITY 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

ANO-1 3.0-3 Amendment No.

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

ANO-1 3.0-34 Amendment No. 215,217,218,

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

ANO-1 3.0-45 Amendment No. 215,232,

Attachment 3 To 1CAN070803 Revised Technical Specification Pages

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.