2CAN030501, Supplement to Amendment Request for License Amendment in Support of Cycle 18 Core Reload

Supplement to Amendment Request for License Amendment in Support of Cycle 18 Core Reload

ML050740442
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/07/2005
From:	James D Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN030501, 2CAN070402
Download: ML050740442 (5)

Text

Entergy Operations, Inc.

- Entergy 1448 S.R. 333 Russellville, AR 72802 Tel 501858 5000 2CAN030501 March 7, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplement to Amendment Request For License Amendment in Support of Cycle 18 Core Reload Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Entergy letter to the NRC dated July 8, 2004, "Supplemental Letter to License Amendment Request to Support Cycle 18 Core Reload' (2CAN070402)

Dear Sir or Madam:

By letter (Reference 1), Entergy Operations, Inc. (Entergy) proposed a change to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TSs) that in part included a request to delete the Index from the TSs.

On March 3, 2005, Entergy and members of your staff held a call to discuss the proposed deletion of the Index. As a result of the call, five questions were determined to need formal response. Entergy's response is contained in Attachment 1.

Entergy requests that the proposed changes to the COLR continue to be processed to support the upcoming refueling outage and that the change to delete the index be deferred, if required.

There are no technical changes proposed. The original no significant hazards consideration included in Reference 1 is not affected by any information contained in the supplemental letter. There are no new commitments contained in this letter.

If you have any questions or require additional information, please contact Dana Millar at 601-368-5445.

ADD/

2CAN030501 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 7, 2005.

Sincerely, ale James Actin Director, Nuclear Safety Assurance DE 1DM Attachments:

1. Response to Request For Additional Information cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, 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. Drew Holland MS 0-7 D1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205

11 Attachment I To 2CAN030501 Response to Request for Additional Information to 2CAN030501 Page 1 of 2 Response to Request for Additional Information Related to License Amendment in Support of Cycle 18 Core Reload Question 1:

The requested amendment is to delete the TS index. The markup shows the Table of Contents (TOC) as deleted. Please clarify change request.

Response 1:

The markup shows the 'index' will be deleted. Arkansas Nuclear One, Unit 2 does not have a heading labeled "Table of Contents" on the pages that were proposed for deletion; "index" is the heading on these pages. Therefore, the proposed change is to delete the uindex."

The intent of the proposed change was to delete the index and maintain it under a licensee controlled program such that changes could be made to the TS index without NRC review and approval. The holders of copies of the TS will receive periodic updates of the TS index pages. The Index update and distribution would be handled in a manner similar to the TS Bases update and distribution. The TS Bases Control Program is included in the ANO-2 TS (TS 6.5.14).

Question 2:

Without a TOC, how will a user of the TS know where in the TS are the requirements that the user wants to read? How will this affect controlled copies in the control room and those distributed to plant personnel, resident inspectors and regional staff?

Response 2:

The user of the TS will continue to have an index as outlined in the response to question 1.

Periodic updates of the index pages will be provided as outlined in response to question 1.

Question 3:

What will be the benefit to the licensee, NRC, and general public in removing the TS Table of Contents? Are there any license amendment precedents for eliminating TS TOCs? Does the NEI Writer's Guide specify guidance for including a TOC for technical specifications?

Response 3:

Removal of the TS index from the 10 CFR 50.90 review process will eliminate unnecessary expenses and time related to the processing and handling of these administrative / non-technical changes. The proposed change would be benefit neutral to the general public since they would continue to have access to an Index.

to 2CAN030501 Page 2 of 2 Entergy is not aware of any license amendment precedents for eliminating the TS Table of Contents or Index, however, when Grand Gulf and Arkansas Nuclear One, Unit I converted to the Improved Standard TSs, both were issued by the NRC without a Table of Contents.

Both plants created and maintain a Table of Contents and periodically provide updated pages to the controlled copy holders.

The Improved Standard Technical Specification Writers guide includes guidance on how to format the Table of Contents page. The Writer's guide refers to the Table of Contents as uTechnical Specification Front Matter," which also includes the Title Page and List of Effective Pages. The Writer's guide describes the Technical Specification content as starting with Chapter 1, "use and Application' and does not include the Table of Contents as part of the content of the TSs.

Question 4:

How would the licensee communicate to the NRC staff, Resident Inspectors, Regional staff and general public numbering changes made to TS sections in the event that the TOC is eliminated?

Response 4:

Please see the response to question 1. Additionally, any numbering changes made on any TS page in TS Sections 1 through 6 would require a license amendment request in accordance with 10 CFR 50.90 which would be distributed as previously described.

Question 5:

Did you consider only eliminating the page numbers and leaving the TOC of the TSs in place?

Response 5:

Entergy intended to maintain the pages with periodic updates and did not consider only eliminating the page numbers.