1CAN102101, SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report

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: 1CAN102101, SAR Amendment 30, TRM, TS Bases, 10 CFR 50.59 Report, and Commitment Change Summary Report
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 Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 John C. Dinelli ANO Site Vice President 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 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 2 of 4 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 - 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 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 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official 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.

Attachment 1 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 Condition Report CR-ANO-C-2018-2844, "Remove 50%

72 3.3.6, B 3.3.6 Allowance of Fire Detection" Licensing Basis Document Change LBDC 20-034, "Update Seismic Monitor TRM to be consistent with 73 B 3.3.2 EPlan Revision 45" and "Common Feedwater TRM Editorial/Clarification Changes" Licensing Basis Document Change LBDC 20-035, "Move from County-Based to Storm-Based Severe Weather 74 3.9.2, B 3.9.2 Warning Areas with respect to Movement of Irradiated Fuel" Licensing Basis Document Change LBDC 21-001, 75 3.10.2, B 3.10.2 "Add Detail Associated with Transportation of FLEX Equipment" Engineering Change EC-84449, "Change from NaOH 76 Table 3.3.5-1 to NaTB" List of Undefined Acronyms FLEX Diverse and Flexible Coping Strategies LBDC License Basis Document Change NaOH Sodium Hydroxide NaTB Sodium Tetraborate

Attachment 2 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, Licensing Basis Document Change LBDC 20-015, B 3.8.7, B 3.8.9 "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" Engineering Change EC-88598, "Extend Integrated 72 B 3.8.1 ES Test Frequency from 18 to 36 Months" Engineering Change EC-76493, "ANO-1 Degraded Voltage Modifications" 73 B 3.3.8, B 3.9.4, B 3.9.5 Engineering Change EC-88963, Reactor Vessel Closure Head Studs 74 B 3.3.5, B 3.3.6, B 3.3.7, Engineering Change EC-84449, "Change from B 3.6.5, B 3.6.6 NaOH to NaTB" 75 B 2.1.1, B 3.1.5, B 3.2.5, Engineering Change EC-85503, "ANO-1 Cycle 30 B 3.4.1 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

Attachment 3 1CAN102101 ANO-1 and ANO-2 Commitment Change Summary Report

1CAN102101 Page 1 of 6 ANO-1 and ANO-2 Commitment Change Summary Report Commitment Changed Number Short Title Original Commitment Justification of Change Date Date Due date extension request to revise from Complete the project plan to identify June 3, 2021, to December 31, 2022.

ANO Confirmatory ANO key calculations and correct Letter 0CAN122003, dated December 8, 20125 12/01/2015 12/03/2020 Action Letter deficiencies with dedicated resources, 2020 documents due date extension and EA-16-124 (CAL) project management, and project justification that was discussed with NRC oversight. (DB16) Region IV management on December 7, 2020.

Complete the project plan created in Due date extension request to revise from Action Item ANO-C-2015-2833 CA-25 July 3, 2021, to December 31, 2022.

with dedicated resources, project Letter 0CAN122003, dated December 8, Confirmatory Action management, and project oversight to 20124 12/01/2015 12/03/2020 2020 documents due date extension and Letter reduce the drawing backlog as specified justification that was discussed with NRC in the project plan. (DB15) Region IV management on December 7, 2020.

Validate that all internal flood gaps Due date extension request to revise from identified from the review of June 3, 2021, to December 31, 2022.

documentation for credible flood paths Letter 0CAN122003, dated December 8, Confirmatory Action 19745 06/17/2016 12/08/2020 and the follow-up walk downs have 2020 documents due date extension and Letter been resolved (FP-8). 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 Commitment Changed Number Short Title Original Commitment Justification of Change Date Date 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.

Entergy will follow the guidance 19265 established in Section 11 of NUMARC Finally, this commitment is contained in ANO-1 93-01, "Industry Guidance for both unit's SARs (a codified process).

/ 03/26/2013 02/04/2021 Maintenance Rule Monitoring the Effectiveness of Compliance with the Section 11 of the 19268 Maintenance at Nuclear Power Plants" NUMARC is well engrained into plant ANO-2 Nuclear Management and Resource processes and controlled under 10 CFR Council, Revision 4A, April 2011. 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 Commitment Changed Number Short Title Original Commitment Justification of Change Date Date Consistent with the ANO-1 NPO calculation, ANO Decay Heat Removal (DHR) and Low Temperature Performance-Based ANO-1 NFPA 805 Table S2 Item S2 Overpressure (LTOP) System Control Standard for Fire Revise existing procedure(s) or develop procedure has been revised to include Protection for Light Water new procedure(s) for Non-Power 19410 01/29/2014 02/04/2021 Reactor Electric Operation (NPO) required to transition protective actions to assist in fire prevention when in reduced inventory.

Generating Plants to NFPA 805 based upon insights This was a one-time action to fulfill this (NFPA-805) gained from ANO-1 NPO calculation.

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 Commitment Changed Number Short Title Original Commitment Justification of Change Date Date 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 Entergy shall review changes to the remaining 3rd and 4th 10-year interval Risk-Informed plant, operational practices, applicable (the fourth interval was extended and Categorization and plant, and industry operational concluded on March 25, 2021).

Treatment for experience, and, as appropriate, update ANO-2 is currently in the 5th 10-year Repair/Replacement 18755 02/20/2008 09/14/2021 Activities in Class 2 and 3 the probabilistic risk assessment (PRA) interval, which started on March 26, 2020.

and categorization and treatment Based on this, this relief is no longer valid, SystemsSection XI, processes in a timely manner, but no and the commitment can be closed.

Division 1 (ASME Code longer than once every two refueling Case N-752) It should be noted the NRC recently outages.

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 Commitment Changed Number Short Title Original Commitment Justification of Change Date Date 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 Prior to removal of the Automatic addition, the procedures contain Closure Interlock (ACI) function, operational requirements that are Operations procedures will be revised governed under 10 CFR 50.59 (a codified Low Temperature to ensure Low Temperature process) and any change to this 18154 07/08/2004 02/04/2021 Overpressure (LTOP) Overpressure (LTOP) relief valves are procedure is controlled effectively and TS Change Request in service prior to placing SDC in evaluated as appropriate within the service and SDC is removed from Entergy procedure change process.

service prior to removing the LTOPS Finally, the ACI function was never from service. 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 Commitment Changed Number Short Title Original Commitment Justification of Change Date Date 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 Spent Fuel Pool (SFP) Ensure appropriate procedures are in considered accident conditions with credit 17976 11/21/2003 02/04/2021 Temperature TS Change place to meet the minimum Spent Fuel for the soluble boron in the pool water as Request Pool (SFP) temperature of 68 °F. 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).

The ANO-1 NaOH system was replaced Request license amendment which will by a NaTB system in 1R29. The current Sodium Hydroxide establish a NaOH concentration upper TS associated with NaOH was approved 16767 02/16/2000 03/30/2021 (NaOH) Tank TS Change analytical pH limit if NaOH tank is ever for deletion (replaced by requirements for Request modified to enlarge its volume above NaTB) in TS Amendment 271. Therefore, the limit. this commitment is no longer relevant and may be closed.

Attachment 4 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 Enclosure 1 1CAN102101 ANO-1 SAR Amendment 30 Un-redacted Version (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.

Enclosure 2 1CAN102101 ANO-1 SAR Amendment 30 Redacted Version (CD Rom) 1CAN102101 ANO-1 TRM (CD Rom)

Enclosure 4 1CAN102101 ANO-1 TS Table of Contents and TS Bases (CD Rom)