1CAN102101, SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report
| ML21288A072 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/06/2021 |
| From: | Dinelli J Entergy Operations |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21288A071 | List: |
| References | |
| 1CAN102101 | |
| Download: ML21288A072 (22) | |
Text
SECURITY-RELATED INFORMATION SAR SECTIONS 2.11.1, 2.11.2, AND 2.11.3 OF ENCLOSURE 1 TO BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 SECURITY-RELATED INFORMATION - WITHOLD UNDER 10 CFR 2.390 DOCUMENTS TRANSMITTED HEREWITH CONTAIN SENSITIVE, UNCLASSIFIED INFORMATION. WHEN SEPARATED FROM THE SENSITIVE INFORMATION, THIS DOCUMENT IS DECONTROLLED.
10 CFR 50.4(b)(6) 10 CFR 50.59(d)(2) 10 CFR 50.71(e) 10 CFR 54.37(b) 1CAN102101 October 6, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
ANO Unit 1 SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report Arkansas Nuclear One, Unit 1 NRC Docket No. 50-313 Renewed Facility Operating License No. DPR-51 In accordance with 10 CFR 50.71(e) and 10 CFR 50.4(b)(6), enclosed is an electronic copy of Amendment 30 to the Arkansas Nuclear One, Unit 1 (ANO-1) Safety Analysis Report (SAR).
Included with this update is an electronic copy of the current ANO-1 Technical Requirements Manual (TRM) and the current ANO-1 Technical Specification (TS) Bases. The TS Bases file also includes the Table of Contents which outlines the contents of both the TSs and the TS Bases, since the Table of Contents is revised by the licensee in accordance with 10 CFR 50.59.
Pursuant to 10 CFR 50.71(e)(4), these documents are being submitted within six months following the previous ANO-1 refueling outage (1R29) which ended May 9, 2021. Summaries of changes to the ANO-1 TRM and TS Bases are included in Attachments 1 and 2 of this letter, respectively. The SAR, TS Bases, and TRM changes enclosed are for the period beginning May 5, 2020 and ending October 6, 2021.
In accordance with NEI 98-03, Appendix A, Section A6, a list and short description of information removed from the SAR should be included with each SAR update submittal. For this reporting period, information was not removed from the SAR meeting the criteria of either Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 John C. Dinelli ANO Site Vice President
SECURITY-RELATED INFORMATION SAR SECTIONS 2.11.1, 2.11.2, AND 2.11.3 OF ENCLOSURE 1 TO BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 1CAN102101 Page 2 of 4 SECURITY-RELATED INFORMATION - WITHOLD UNDER 10 CFR 2.390 DOCUMENTS TRANSMITTED HEREWITH CONTAIN SENSITIVE, UNCLASSIFIED INFORMATION. WHEN SEPARATED FROM THE SENSITIVE INFORMATION, THIS DOCUMENT IS DECONTROLLED.
Appendix A, Sections A4 or A5, of NEI 98-03, that would require reporting in accordance with NEI 98-03, Appendix A, Section A6.
Associated in part with post September 11, 2001, response related to security sensitive information, Entergy has reviewed the ANO-1 SAR and determined that the following items contain information required to be withheld from public disclosure with respect to NRC Regulatory Issue Summary (RIS) 2015-17, "Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents."
SAR Section 2.11.1 "Maximum Probable Flood" SAR Section 2.11.2 "Failure of Upstream Dams" SAR Section 2.11.3 "Design Flood Evaluation" The above is consistent with currently redacted information from the ANO-1 SAR (reference ML20133J852). Entergy requests the aforementioned information be withheld from public disclosure in accordance with 10 CFR 2.390. Accordingly, a complete version and a redacted version of the ANO-1 SAR are included on the enclosed compact disc (CD).
In accordance with 10 CFR 54.37(b), after a renewed license is issued, the SAR update required by 10 CFR 50.71(e) must include any systems, structures, and components (SSCs) newly identified that would have been subject to an aging management review or evaluation of time-limited aging analyses in accordance with 10 CFR 54.21. The SAR update must describe how the effects of aging will be managed such that the intended function(s) in 10 CFR 54.4(b) will be effectively maintained during the period of extended operation. No SAR changes were required with respect to 10 CFR 54.37(b) during this reporting period. It should be noted that during this update period, SAR Section 16.2.21.7 "Sodium Hydroxide (NaOH) Tank Level Monitoring" was deleted due to installation of the Sodium Tetraborate (NaTB) baskets and abandonment of the NaOH tank.
In accordance with 10 CFR 50.59(d)(2), a report containing a brief description of any changes, tests, and experiments must be submitted at intervals not to exceed 24 months. During this reporting period, there were no ANO-1 10 CFR 50.59 evaluations and no evaluations common between ANO-1 and ANO Unit 2 (ANO-2) that were associated with changes to Licensing Basis Documents.
contains a summary of changes to regulatory commitments which have occurred over the reporting period.
includes a list of SAR pages that were updated during the period.
If you have any questions or require additional information, please contact Riley Keele at 479-858-7826.
SECURITY-RELATED INFORMATION SAR SECTIONS 2.11.1, 2.11.2, AND 2.11.3 OF ENCLOSURE 1 TO BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 1CAN102101 Page 3 of 4 I hereby certify that to the best of my knowledge and belief, the information contained in the above Licensing Basis Documents accurately reflects changes made since the previous submittal. The changes to these documents reflect information and analyses submitted to the Commission, prepared pursuant to Commission requirements, or made under the provisions of 10 CFR 50.59. Executed on October 6, 2021
- 1. Summary of ANO-1 TRM Changes
- 2. Summary of ANO-1 TS Bases Changes
- 3. ANO-1 and ANO-2 Commitment Change Summary Report
- 4. List of Affected SAR Pages Enclosures (compact disc):
- 1. ANO-1 SAR Amendment 30 - Un-redacted Version (CD Rom)
- 2. ANO-1 SAR Amendment 30- Redacted Version (CD Rom)
- 3. ANO-1 TRM (CD Rom)
- 4. ANO-1 TS Table of Contents and TS Bases (CD Rom)
SECURITY-RELATED INFORMATION -WITHOLD UNDER 10 CFR 2.390 DOCUMENTS TRANSMITTED HEREWITH CONTAIN SENSITIVE, UNCLASSIFIED INFORMATION. WHEN SEPARATED FROM THE SENSITIVE INFORMATION, THIS DOCUMENT IS DECONTROLLED.
SECURITY-RELATED INFORMATION SAR SECTIONS 2.11.1, 2.11.2, AND 2.11.3 OF ENCLOSURE 1 TO BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 1CAN102101 Page 4 of 4 SECURITY-RELATED INFORMATION - WITHOLD UNDER 10 CFR 2.390 DOCUMENTS TRANSMITTED HEREWITH CONTAIN SENSITIVE, UNCLASSIFIED INFORMATION. WHEN SEPARATED FROM THE SENSITIVE INFORMATION, THIS DOCUMENT IS DECONTROLLED.
cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official
1CAN102101 Summary of ANO-1 TRM Changes
1CAN102101 Page 1 of 1 Summary of ANO-1 TRM Changes The following changes to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Requirements Manual (TRM) were implemented in accordance with the provisions of 10 CFR 50.59. Because these changes were implemented without prior NRC approval, a description is provided below:
Revision #
TRM Section Description of Change 72 3.3.6, B 3.3.6 Condition Report CR-ANO-C-2018-2844, "Remove 50%
Allowance of Fire Detection" 73 B 3.3.2 Licensing Basis Document Change LBDC 20-034, "Update Seismic Monitor TRM to be consistent with EPlan Revision 45" and "Common Feedwater TRM Editorial/Clarification Changes" 74 3.9.2, B 3.9.2 Licensing Basis Document Change LBDC 20-035, "Move from County-Based to Storm-Based Severe Weather Warning Areas with respect to Movement of Irradiated Fuel" 75 3.10.2, B 3.10.2 Licensing Basis Document Change LBDC 21-001, "Add Detail Associated with Transportation of FLEX Equipment" 76 Table 3.3.5-1 Engineering Change EC-84449, "Change from NaOH to NaTB" List of Undefined Acronyms FLEX Diverse and Flexible Coping Strategies LBDC License Basis Document Change NaOH Sodium Hydroxide NaTB Sodium Tetraborate
1CAN102101 Summary of ANO-1 TS Bases Changes
1CAN102101 Page 1 of 1 Summary of ANO-1 TS Bases Changes The following changes to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specification (TS) Bases were implemented in accordance with the provisions of 10 CFR 50.59 and the Bases Control Program of ANO-1 TS 5.5.14. Because these changes were implemented without prior NRC approval, a description is provided below:
Revision #
TS Bases Section Description of Change 71 B 3.4.5, B 3.8.1, B 3.8.4, B 3.8.7, B 3.8.9 Licensing Basis Document Change LBDC 20-015, "Corrected Criterion Reference in B3.4.5, Corrected Time to Mode 3 to match actual TS Completion Time for B3.8.1, B3.8.4, B3.8.7, and B3.8.9" 72 B 3.8.1 Engineering Change EC-88598, "Extend Integrated ES Test Frequency from 18 to 36 Months" 73 B 3.3.8, B 3.9.4, B 3.9.5 Engineering Change EC-76493, "ANO-1 Degraded Voltage Modifications" Engineering Change EC-88963, Reactor Vessel Closure Head Studs 74 B 3.3.5, B 3.3.6, B 3.3.7, B 3.6.5, B 3.6.6 Engineering Change EC-84449, "Change from NaOH to NaTB" 75 B 2.1.1, B 3.1.5, B 3.2.5, B 3.4.1 Engineering Change EC-85503, "ANO-1 Cycle 30 Reload Report and COLR" List of Undefined Acronyms COLR Core Operating Limits Report ES Engineered Safeguards LBDC License Basis Document Change NaOH Sodium Hydroxide NaTB Sodium Tetraborate
1CAN102101 ANO-1 and ANO-2 Commitment Change Summary Report
1CAN102101 Page 1 of 6 ANO-1 and ANO-2 Commitment Change Summary Report Number Commitment Date Changed Date Short Title Original Commitment Justification of Change 20125 12/01/2015 12/03/2020 ANO Confirmatory Action Letter EA-16-124 (CAL)
Complete the project plan to identify ANO key calculations and correct deficiencies with dedicated resources, project management, and project oversight. (DB16)
Due date extension request to revise from June 3, 2021, to December 31, 2022.
Letter 0CAN122003, dated December 8, 2020 documents due date extension and justification that was discussed with NRC Region IV management on December 7, 2020.
20124 12/01/2015 12/03/2020 Confirmatory Action Letter Complete the project plan created in Action Item ANO-C-2015-2833 CA-25 with dedicated resources, project management, and project oversight to reduce the drawing backlog as specified in the project plan. (DB15)
Due date extension request to revise from July 3, 2021, to December 31, 2022.
Letter 0CAN122003, dated December 8, 2020 documents due date extension and justification that was discussed with NRC Region IV management on December 7, 2020.
19745 06/17/2016 12/08/2020 Confirmatory Action Letter Validate that all internal flood gaps identified from the review of documentation for credible flood paths and the follow-up walk downs have been resolved (FP-8).
Due date extension request to revise from June 3, 2021, to December 31, 2022.
Letter 0CAN122003, dated December 8, 2020 documents due date extension and justification that was discussed with NRC Region IV management on December 7, 2020.
1CAN102101 Page 2 of 6 ANO-1 and ANO-2 Commitment Change Summary Report Number Commitment Date Changed Date Short Title Original Commitment Justification of Change 19265 ANO-1
/
19268 ANO-2 03/26/2013 02/04/2021 Maintenance Rule Entergy will follow the guidance established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" Nuclear Management and Resource Council, Revision 4A, April 2011.
Procedure EN-DC-203, "Maintenance Rule Program," references NUMARC 93-01, as endorsed by Regulatory Guide (RG) 1.160, as the governing guidance for the Entergy Maintenance Rule program.
In addition, each unit's Technical Specifications (TS) Bases associated with risk assessments tied to mode restraints/changes specify the use of NUMARC 93-01, Section 11.
Finally, this commitment is contained in both unit's SARs (a codified process).
Compliance with the Section 11 of the NUMARC is well engrained into plant processes and controlled under 10 CFR 50.59 (being referenced in the SAR). No change to the procedures is performed as a result of this commitment closure.
Based on the above, it is no longer necessary to track this regulatory commitment within CMS.
This commitment change only halts tracking of the requirement as a regulatory commitment, given the controls that exist for SAR changes.
1CAN102101 Page 3 of 6 ANO-1 and ANO-2 Commitment Change Summary Report Number Commitment Date Changed Date Short Title Original Commitment Justification of Change 19410 01/29/2014 02/04/2021 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (NFPA-805)
ANO-1 NFPA 805 Table S2 Item S2 Revise existing procedure(s) or develop new procedure(s) for Non-Power Operation (NPO) required to transition to NFPA 805 based upon insights gained from ANO-1 NPO calculation.
Consistent with the ANO-1 NPO calculation, ANO Decay Heat Removal (DHR) and Low Temperature Overpressure (LTOP) System Control procedure has been revised to include protective actions to assist in fire prevention when in reduced inventory.
This was a one-time action to fulfill this regulatory commitment and it was completed; therefore, this commitment may be closed.
1CAN102101 Page 4 of 6 ANO-1 and ANO-2 Commitment Change Summary Report Number Commitment Date Changed Date Short Title Original Commitment Justification of Change 18755 02/20/2008 09/14/2021 Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 SystemsSection XI, Division 1 (ASME Code Case N-752)
Entergy shall review changes to the plant, operational practices, applicable plant, and industry operational experience, and, as appropriate, update the probabilistic risk assessment (PRA) and categorization and treatment processes in a timely manner, but no longer than once every two refueling outages.
2CAN020804, "Responses to Request for Additional Information (RAI) Request for Alternative ANO-2-R&R-004, Revision 1" provided responses to RAIs concerning relief request ANO2-R&R-004. This relief request was submitted to the NRC via CNRO-2007-00015. The relief request was to use risk-informed categorization and treatment for repair/replacement activities in Class 2 and 3 moderate energy systems. The request was for the third and future 10-year intervals at ANO-2. The NRC approved the relief (2CNA040902), but it was limited to the remaining 3rd and 4th 10-year interval (the fourth interval was extended and concluded on March 25, 2021).
ANO-2 is currently in the 5th 10-year interval, which started on March 26, 2020.
Based on this, this relief is no longer valid, and the commitment can be closed.
It should be noted the NRC recently approved the use of Code Case N-752 for ANO (ML21118B039). This code case is very similar to the relief request discussed above. A similar commitment was made for Code Case N-752 and it has been implemented. New commitment P-20285:
Entergy shall review changes to the plant, operational practices, applicable plant and industry operational experience, and as appropriate, update the PRA and categorization and treatment processes.
Entergy shall perform this review in a timely manner but no longer than once every two refueling outages.
1CAN102101 Page 5 of 6 ANO-1 and ANO-2 Commitment Change Summary Report Number Commitment Date Changed Date Short Title Original Commitment Justification of Change 18154 07/08/2004 02/04/2021 Low Temperature Overpressure (LTOP)
TS Change Request Prior to removal of the Automatic Closure Interlock (ACI) function, Operations procedures will be revised to ensure Low Temperature Overpressure (LTOP) relief valves are in service prior to placing SDC in service and SDC is removed from service prior to removing the LTOPS from service.
This commitment has been controlled via procedures for over 15 years and is well engrained into plant operations. No change to the procedures is performed as a result of this commitment closure. In addition, the procedures contain operational requirements that are governed under 10 CFR 50.59 (a codified process) and any change to this procedure is controlled effectively and evaluated as appropriate within the Entergy procedure change process.
Finally, the ACI function was never credited in any accident analyses, supporting the conclusion that this commitment is a defense-in-depth measure only. Based on the above, it is no longer necessary to track this regulatory commitment within CMS.
1CAN102101 Page 6 of 6 ANO-1 and ANO-2 Commitment Change Summary Report Number Commitment Date Changed Date Short Title Original Commitment Justification of Change 17976 11/21/2003 02/04/2021 Spent Fuel Pool (SFP)
Temperature TS Change Request Ensure appropriate procedures are in place to meet the minimum Spent Fuel Pool (SFP) temperature of 68 °F.
This commitment was associated with TS changes supporting an increase in fuel enrichment in the ANO-1 SFP and the use of Metamic inserts. In Region 3 of the SFP, the moderator temperature coefficient (MTC) is negative and the design basis temperature was assumed to be 20 °C (68 °F). Administrative procedures limit the minimum SFP temperature to a minimum of 68 °F. As in the case of temperatures above 150 °F, temperatures below 68 °F are also considered accident conditions with credit for the soluble boron in the pool water as permitted by the NRC guidelines.
Any changes to the associated accident analyses calculations are strictly controlled and require changes to the administrative procedures when needed.
This assures that the reactivity is always maintained within acceptable limits and removes any need to continue to track this minimum temperature as a regulatory commitment.
In addition to the above, the TS amendment request was withdrawn on June 24, 2004 (1CAN060404).
16767 02/16/2000 03/30/2021 Sodium Hydroxide (NaOH) Tank TS Change Request Request license amendment which will establish a NaOH concentration upper analytical pH limit if NaOH tank is ever modified to enlarge its volume above the limit.
The ANO-1 NaOH system was replaced by a NaTB system in 1R29. The current TS associated with NaOH was approved for deletion (replaced by requirements for NaTB) in TS Amendment 271. Therefore, this commitment is no longer relevant and may be closed.
1CAN102101 List of Affected SAR Pages
1CAN102101 Page 1 of 2 List of Affected SAR Pages The following is a list of Safety Analysis Report (SAR) pages revised in Amendment 30 to support corrections, modifications, implementation of licensing basis changes, etc., as described in the Table of Contents of each SAR chapter (reference Enclosure 1 of this letter).
Information relocated from one page to another in support of the aforementioned revisions is not considered a change; therefore, these pages are not included in the following list. In addition, pages associated with the individual Table of Contents are not listed below as related revisions are administrative only changes.
Cover Page 3A.9-3 Figure 3A-11 6.7-4 1.2-2 3A.10-1 Figure 3A-12 6.7-5 1.4-11 3A.10-2 Figure 3A-13 6.7-8 1.5-4 3A.11-1 Figure 3A-14 6.7-9 1.11-1 3A.11-2 Figure 3A-15A 6.7-10 1.11-6 3A.11-3 Figure 3A-15B 6.7-11 3.4-5 3A.11-4 Figure 3A-15C Figure 6-1 3.4-7 3A.11-5 Figure 3A-16A 7.1-16 3A.1-1 3A.11-6 Figure 3A-16B 7.1-17 3A.1-2 3A.11-7 Figure 3A-16C 7.6-3 3A.2-1 3A.11-8 Figure 3A-17A 7.6-4 3A.3-1 3A.11-9 Figure 3A-17B 8.3-14 3A.4-1 3A.11-10 Figure 3A-17C 8.3-20 3A.4-2 3A.11-11 Figure 3A-18 8.3-21 3A.4-3 3A.11-12 Figure 3A-19 8.3-22 3A.4-4 Figure 3A-1 5.1-15 8.3-23 3A.4-5 Figure 3A-2 6.1-1 8.3-24 3A.5-1 Figure 3A-3 6.1-2 8.3-25 3A.5-2 Figure 3A-4 6.1-11 8.4-1 3A.6-1 Figure 3A-5 6.2-1 9.3-4 3A.7-1 Figure 3A-6 6.2-3 9.6-4 3A.7-2 Figure 3A-7 6.2-4 9.8-7 3A.7-3 Figure 3A-8 6.2-5 9.8-13 3A.8-1 Figure 3A-9 6.2-6 9.8-18 3A.8-2 Figure 3A-10 6.6-2 Figure 9-4
1CAN102101 Page 2 of 2 11.1-6 Figure 11-1 14.2-55 16.1-3 16.2-2 16.2-3 16.2-12
SECURITY-RELATED INFORMATION SAR SECTIONS 2.11.1, 2.11.2, AND 2.11.3 OF ENCLOSURE 1 TO BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 SECURITY-RELATED INFORMATION - WITHOLD UNDER 10 CFR 2.390 DOCUMENTS TRANSMITTED HEREWITH CONTAIN SENSITIVE, UNCLASSIFIED INFORMATION. WHEN SEPARATED FROM THE SENSITIVE INFORMATION, THIS DOCUMENT IS DECONTROLLED.
1CAN102101 ANO-1 SAR Amendment 30 Un-redacted Version (CD Rom)
1CAN102101 ANO-1 SAR Amendment 30 Redacted Version (CD Rom)
1CAN102101 ANO-1 TRM (CD Rom)
1CAN102101 ANO-1 TS Table of Contents and TS Bases (CD Rom)