2CAN010902, License Amendment Request Supplemental Regarding Technical Specification Changes for Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

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License Amendment Request Supplemental Regarding Technical Specification Changes for Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process
ML090130131
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 01/12/2009
From: Mitchell T
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN010902, TAC MD7175
Download: ML090130131 (8)


Text

2CAN010902 January 12, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request Supplemental Regarding Technical Specification Changes for Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCE:

1.

Entergy letter to NRC dated October 22, 2007, Technical Specification Changes For Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (2CAN100702) (TAC No. MD7175)

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90, Entergy Operations, Inc. (Entergy) submitted a request for an amendment (Reference 1) to the Technical Specifications (TS) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed amendment would modify TS requirements related to control room envelope (CRE) habitability in accordance with Technical Specification Task Force (TSTF)-448, Revision 3, using the consolidated line item improvement process (CLIIP).

In the original letter (Reference 1), Entergy proposed to control the first performance of CRE tests adopted via TSTF-448 by regulatory commitment. However, The NRC notified Entergy in late December 2008 that the first performance of CRE testing must be controlled in the Operating License. Therefore, Entergy proposes to delete commitments contained in its original letter (Reference 1) associated with the first performance of CRE testing and add a new ANO-2 Operating License condition 2.C.(11) to capture the requirements for the first performance of these tests. A markup of the affected Operating License page is included in. Incorporation of these test requirements into the Operating License required existing information to be moved to subsequent pages. Therefore, Attachment 1 includes Pages 7 and 8, and a new Page 9 to the Operating License. Because Pages 8 and 9 contain only relocated information, revision bars are not included. Note that the markup refers to an Amendment xxx, where xxx represents the Amendment number approving the adoption of TSTF-448 for ANO-2.

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Timothy G. Mitchell Vice President, Operations Arkansas Nuclear One

2CAN010902 Page 2 of 2 contains a revised List of Regulatory Commitments.

The adoption of Operating License requirements for the first performance of CRE testing and the revision to the List of Regulatory Commitments table do not invalidate the No Significant Hazards Considerations associated with the original ANO-2 submittal (Reference 1).

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

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 January 12, 2009.

Sincerely, TGM/dbb

Attachment:

1.

ANO-2 Operating License Markup Pages

2.

Revised List of Regulatory Commitments 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 Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

To 2CAN010902 ANO-2 Operating License Markup Pages

7 Renewed License No. NPF-6 Amendment No.

Revised by letter dated July 18, 2007 (10) Mitigation Strategies The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas:

(i)

Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance

2.

Assessment of mutual aid fire fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and control

5.

Training of response personnel (ii) Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread

4.

Procedures for implementing integrated fire response strategy

5.

Identification of readily-available pre-staged equipment

6.

Training on integrated fire response strategy

7.

Spent fuel pool mitigation measures (iii) Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders (11) Upon implementation of Amendment xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.6.1.2.d, in accordance with Specifications 6.5.12.c.(i),

6.5.12.c.(ii), and 6.5.12.d, shall be considered met. Following implementation:

(i)

The first performance of SR 4.7.6.1.2.d, in accordance with Specification 6.5.12.c.(i), shall be within 15 months of the approval of TSTF-448. SR 4.0.2 will not be applicable to this first performance.

(ii) The first performance of the periodic assessment of CRE habitability, Specification 6.5.12.c.(ii), shall be within 15 months of the approval of TSTF-448. SR 4.0.2 will not be applicable to this first performance.

(iii) The first performance of the periodic measurement of CRE pressure, Specification 6.5.12.d, shall be within 15 months of the approval of TSTF-448. SR 4.0.2 will not be applicable to this first performance.

8 Renewed License No. NPF-6 Amendment No.

Revised by letter dated July 18, 2007 D.

Physical Protection EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Arkansas Nuclear One Physical Security, Safeguards Contingency and Training & Qualification Plan," as submitted on May 4, 2006.

E.

This renewed license is subject to the following additional condition for the protection of the environment:

Before engaging in additional construction or operational activities which may result in an environmental impact that was not evaluated by the Commission, EOI will prepare and record an environmental evaluation for such activity. When the evaluation indicates that such activity may result in a significant adverse environmental impact that was not evaluated, or that is significantly greater than that evaluated, in the Final Environmental Statement (NUREG-0254) or any addendum thereto, and other NRC environmental impact assessments, EOI shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation.

F.

Updated Final Safety Analysis Report Supplement The Final Safety Analysis Report supplement, as revised, shall be included in the next scheduled update to the Final Safety Analysis Report required by 10 CFR 50.71(e)(4) following issuance of this renewed license. Until that update is complete, ANO-2 may make changes to the programs and activities described in the supplement without prior Commission approval, provided that ANO-2 evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements of that section.

The ANO-2 Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to the period of extended operation. ANO-2 shall complete these activities no later than July 17, 2018, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

G.

Reactor Vessel Material Surveillance Capsules All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation.

All capsules placed in storage must be maintained for future insertion.

Renewed License No. NPF-6 Amendment No.

Revised by letter dated February 7, 2007, July 18, 2007

4.

This renewed license is effective as of the date of issuance and shall expire at midnight, July 17, 2038.

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by J. E. Dyer J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:

1.

Appendix A - Technical Specifications

2.

Preoperational Tests, Startup Tests and other items which must be completed by the indicated Operational Mode Date of Issuance: June 30, 2005

To 2CAN010902 Revised List of Regulatory Commitments to 2CAN010902 Page 1 of 1 Revised 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.

COMMITMENT TYPE (Check one)

SCHEDULED COMPLETION DATE (If Required)

ONE-TIME ACTION CONTINUING COMPLIANCE Entergy will establish the Technical Specification (TS) Bases for TS 3.7.6.1, consistent with TSTF 448, Revision 3, as adopted with the applicable license amendment.

X To be implemented with amendment