2CAN011104, Response to the Request for Clarification Regarding License Amendment Request Technical Specification Change to Extend the Type a Test Frequency to 15 Years

Response to the Request for Clarification Regarding License Amendment Request Technical Specification Change to Extend the Type a Test Frequency to 15 Years

ML110210971
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/20/2011
From:	Schwarz C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN011104
Download: ML110210971 (6)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President - Operations Arkansas Nuclear One 2CAN011104 January 20, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to the Request for Clarification Regarding License Amendment Request Technical Specification Change to Extend the Type A Test Frequency to 15 Years Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCE:

Entergy letter dated June 17, 2010, License Amendment Request Technical Specification Change to Extend the Type A Test Frequency to 15 Years (2CAN061003)

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) proposed a change to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS) via the referenced submittal. Specifically, the change would allow for the extension of the ten-year frequency of the ANO-2 Type A or Integrated Leak Rate Test (ILRT) required by TS 6.5.16 to 15 years on a permanent basis.

During a conference call on January 13, 2011, representatives of the NRC staff discussed two clarifications to the referenced submittal with a representative of the ANO Licensing Staff. The first clarification is with regard to the proposed wording of TS 6.5.16. The originally proposed words included the following:

This program shall be in accordance with the guidelines contained in NEI 94-01, Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR part 50, Appendix J, dated October 2008, except that the next Type A test performed after November 30, 2000 Type A test shall be performed no later than November 30, 2015.

The words above, except that were highlighted in this letter for emphasis. The highlighted words above give the appearance that the extension of the Type A Test is the exception to the requirements of NEI 94-01, Revision 2-A. NEI 94-01, Revision 2-A provides the justification to extend the frequency for this test. Entergy is not taking any exceptions to NEI 94-01, Revision 2-A for ANO-2. The highlighted words are deleted and the remaining sentence is divided into two sentences. Attachment 1 provides the revised mark-up page.

2CAN011104 Page 2 of 2 The other item that needed to be clarified is Attachment 4, List of Regulatory Commitments, of the referenced letter. In this attachment, a commitment to use the definition provided in NEI 94-01, Revision 2-A for calculating the Type A leakage rate was denoted as a one-time action.

This should have been denoted as Continuing Compliance. This correction is shown in of this letter.

There are no new commitments in this letter.

If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 20, 2011.

Sincerely, Original signed by Christopher J. Schwarz CJS/rwc Attachments:

1. Proposed Technical Specification Changes (mark-up)

2. 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 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Attachment 1 2CAN011104 Proposed Technical Specification Changes (mark-up)

ADMINISTRATIVE CONTROLS 6.5.16 Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in NEI 94-01, Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, dated October 2008.

Regulatory Guide 1.163, Performance-Based Containment Leak-Test Program, dated September 1995, except that tThe next Type A test performed after the November 30, 2000 Type A test shall be performed no later than November 30, 2015February 29, 2012.

In addition, the containment purge supply and exhaust isolation valves shall be leakage rate tested prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 58 psig.

The maximum allowable containment leakage rate, La, shall be 0.1% of containment air weight per day at Pa.

Leakage rate acceptance criteria are:

a. Containment leakage rate acceptance criteria is 1.0 La. During the first unit startup following each test performed in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and Type C tests and 0.75 La for Type A tests.

b. Air lock acceptance criteria are:

1. Overall air lock leakage rate is 0.05 La when tested at Pa.

2. Leakage rate for each door is 0.01 La when pressurized to 10 psig.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the Containment Leakage Rate Testing Program.

ARKANSAS - UNIT 2 6-18 Amendment No. 255,284,

Attachment 2 2CAN011104 List of Regulatory Commitments to 2CAN011104 Page 1 of 1 List of Regulatory Commitments This table identifies actions discussed in this letter for which Entergy commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.

TYPE (Check one) SCHEDULED COMMITMENT COMPLETION DATE ONE-TIME CONTINUING (If Required)

ACTION COMPLIANCE ANO will use the definition in Section 5.0 X Upon NRC of NEI 94-01, Revision 2-A, for calculating approval of this the Type A leakage rate License Amendment Request (LAR)