1CAN070804, License Amendment Request Regarding Technical Specification Changes Associated with Adoption of TSTF-359

License Amendment Request Regarding Technical Specification Changes Associated with Adoption of TSTF-359

ML082040897
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
1CAN070804, TAC MD7179
Download: ML082040897 (7)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Timothy G. Mitchell Vice President, Operations Arkansas Nuclear One 1CAN070804 July 21, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request Regarding Technical Specification Changes Associated with Adoption of TSTF-359 Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCES:

1. Entergy letter dated October 22, 2007, License Amendment Request: Technical Specification Changes Regarding Mode Change Limitations and Associated Bases Using the Consolidated Line Item Improvement Process (1CAN100701) (TAC NO: MD7179)

2. NRC letter dated April 2, 2008, Arkansas Nuclear One, Unit No. 1 -

Issuance of Amendment Re: Technical Specification Task Force (TSTF) change TSTF-359, Increased Flexibility in Mode Restraints (1CNA040801) (TAC NO: MD7179)

Dear Sir or Madam:

By letter (Reference 1), Entergy Operations, Inc. (Entergy) proposed a change to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TSs) to support adoption of Technical Specification Task Force (TSTF) 359, Increased Flexibility in Mode Restraints.

The NRC approved adoption of TSTF-359 for ANO-1 in TS Amendment 232 (Reference 2).

The overall intent of TSTF-359 was to eliminate exceptions to Limiting Condition for Operation (LCO) 3.0.4 within individual specifications and provide requirements within LCO 3.0.4 to control mode changes when TS-required equipment is inoperable. Following implementation of TS Amendment 232, Entergy discovered that one of the marked-up TS pages which contained an LCO 3.0.4 exception was not provided to the NRC for review in the original submittal (Reference 1) and subsequently was not included in the NRC-approved TS amendment (Reference 2). Therefore, Entergy is submitting this omitted page for NRC review and approval in order to maintain consistency with the intent of TSTF-359.

1CAN070804 Page 2 of 3 The omitted page involves an LCO 3.0.4 exception to the 30-day allowable outage time of the Startup No. 2 Transformer in TS 3.8.1. The page was identified and electronically marked-up at the time of original letter was drafted. However, this particular LCO 3.0.4 exception was not denoted in TSTF-359 because the exception is associated with an ANO specific application of maintenance related to Startup No. 2 Transformer. This transformer is shared between the ANO units and the 30-day allowable outage time to support maintenance is not generic to the industry; therefore, it is not included in the standard TSs of NUREG-1430 for Babcock & Wilcox plants.

In light of the above, it was not readily apparent that an affected page was missing when the final comparison of the Entergy letter to the TSTF-359 mark-ups was completed prior to transmitting to the NRC. The aforementioned omission has been entered into the ANO Corrective Action Process.

Upon identification, the omitted page was immediately discussed with the ANO-1 NRC Project Manager and it was concluded that a new TS amendment would be necessary.

Because the application of TSTF-359 has already been approved for ANO-1, the NRC agreed that an explanation of the omission be included in a cover letter, the omitted page included in attachment, and that no further justification would be required. Note that, given the new wording of LCO 3.0.4 following TSTF-359 adoption, an LCO 3.0.4 exception (i.e.,

stating that LCO 3.0.4 is not applicable) in an individual specification is invalidated.

In addition to the above, a typographical error was noted on the affected page and is corrected as part of this submittal (the term operability is mis-spelled in the Completion Time for Required Action B.2). This change is administrative in nature and requires no further justification.

The mark-up of the omitted page is included in Attachment 1. Attachment 2 provides the revised (clean) version of the page. Because the current TS 3.8.1 Bases do not include discussion of the aforementioned LCO 3.0.4 exception, no TS Bases change are required.

Although the proposed change is neither emergency or exigent, Entergy requests review and approval of the proposed change as soon as reasonably practical in order to establish consistency with the intent of TSTF-359 and the recently approved ANO-1 TS Amendment 232.

There are no new commitments contained in this letter.

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

1CAN070804 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on July 21, 2008.

Sincerely, TGM/dbb Attachments:

1. Proposed Technical Specification Change (mark-up)

2. Revised Technical Specification Page 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 1CAN070804 Proposed Technical Specification Change (mark-up)

AC Sources - Operating 3.8.1 CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 ------------NOTE-----------------

Startup Transformer No. 2 may be removed from service for up to 30 days for preplanned preventative maintenance. This 30 day Completion Time may be applied not more than once in any 10 year period. The provisions of LCO 3.0.4 are not applicable to Startup Transformer No. 2 during this 30 day preventative maintenance period.

Restore required offsite 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> circuit to OPERABLE status. AND 10 days from discovery of failure to meet LCO B. One DG inoperable. B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OPERABLE required offsite circuit(s). 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 B.2 Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from supported by the discovery of inoperable DG inoperable Condition B when its redundant concurrent with required feature(s) is inoperability of inoperable. redundant required feature(s)

AND B.3.1 Determine OPERABLE DG 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not inoperable due to common cause failure.

OR ANO-1 3.8.1-2 Amendment No. 215,

Attachment 2 To 1CAN070804 Revised Technical Specification Page

AC Sources - Operating 3.8.1 CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 ------------NOTE-----------------

Startup Transformer No. 2 may be removed from service for up to 30 days for preplanned preventative maintenance. This 30 day Completion Time may be applied not more than once in any 10 year period.

Restore required offsite 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> circuit to OPERABLE status. AND 10 days from discovery of failure to meet LCO B. One DG inoperable. B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OPERABLE required offsite circuit(s). 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 B.2 Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from supported by the discovery of inoperable DG inoperable Condition B when its redundant concurrent with required feature(s) is inoperability of inoperable. redundant required feature(s)

AND B.3.1 Determine OPERABLE DG 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not inoperable due to common cause failure.

OR ANO-1 3.8.1-2 Amendment No. 215,