2CAN040805, Supplemental to License Amendment Request, Technical Specification Changes Regarding Mode Change Limitations and Associated Bases Using the Consolidated Line Item Improvement Process

Supplemental to License Amendment Request, Technical Specification Changes Regarding Mode Change Limitations and Associated Bases Using the Consolidated Line Item Improvement Process

ML081160053
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/22/2008
From:	Mitchell T Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN040805
Download: ML081160053 (14)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Timothy G. Mitchell Vice President, Operations Arkansas Nuclear One 2CAN040805 April 22, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplemental to License Amendment Request Technical Specification Changes Regarding Mode Change Limitations and Associated Bases Using the Consolidated Line Item Improvement Process Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCE:

1. License Amendment Request - Technical Specification Changes Regarding Mode Change Limitations and Associated Bases Using the Consolidated Line Item Improvement Process (2CAN100701)

Dear Sir or Madam:

By letter dated October 22, 2007 (Reference 1), Entergy Operations, Inc. (Entergy) requested adoption of Technical Specification Task Force (TSTF)-359, Revision 9, for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed amendment would modify Technical Specification (TS) requirements for mode change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 4.0.4. The modification of these specifications results in changes to various other ANO-2 TSs as described in the attachments to this submittal.

On Page 3 of Attachment 1, Page 1 of Attachment 4, and in the markup of the proposed Technical Specification (TS) Bases included in Attachment 5 of the original submittal (Reference 1), statements are made limiting the time in which hot-testing of Pressurizer Safety Valves may be accomplished to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> total. The intent of the TS was to permit up to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> to perform this testing for each valve, thus permitting up to a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to complete testing of both valves. The 36-hour allowance is consistent with the allowance provided in TS 3.4.10 of the improved standard TSs for Combustion Engineering Plants (NUREG 1432, Rev. 3.1). Therefore, following conversation with the NRC on April 21, 2008, Entergy agreed to revising the submittal to change the summed or total time permitted to support valve testing at hot conditions to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

In addition to the above, the NRC requested that consideration be given to removing reference to LCO 3.0.4 in TS 3.8.1, AC Sources, Action A.2. This Action permits the Startup #2 Transformer to be removed from service for up to 30 days under certain conditions and contains a statement that LCO 3.0.4 is not applicable to the 30-day allowed outage time, as

2CAN040805 Page 2 of 3 approved by the NRC in ANO-2 TS Amendment 215, dated April 28, 2000. Because the new LCO 3.0.4.b provides an acceptable method of supporting a change in plant mode with the transformer inoperable, Entergy proposes to delete the LCO exception statement from Action A.2. The associated TS Bases page did not discuss LCO 3.0.4 and, therefore, no new or revised TS Bases page is necessary for this change.

Based on the above, a revised Page 3 and 4 of Attachment 1, a revised markup of TS page 3/4 8-1 of Attachment 2, a revised clean page of TS page 3/4 8-1 of Attachment 3, a revised Page 1 of Attachment 4, and a revised TS Bases page for Pressurizer Safety Valves as contained in the original submittal (Reference 1) are included in Attachments 1, 2, 3, 4, and 5 of this supplemental, respectively. The new pages clarify the summed time for hot testing to be no longer than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and indicate the deletion of the LCO 3.0.4 exception associated with Startup Transformer #2. These pages may be used as replacement pages for those of the original submittal (Reference 1).

The proposed change includes a revised commitment, as described in Attachment 4 of this submittal.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 22, 2008.

Sincerely, TGM/dbb Attachments:

1. Analysis of Proposed Technical Specification Change - Replacement Pages

2. Proposed Technical Specification Changes (mark-up) - Replacement Page

3. Revised Technical Specification Pages - Replacement Page

4. List of Regulatory Commitments - Replacement Page

5. Proposed Technical Specification Bases Changes (mark-up) - Replacement and New Page

2CAN040805 Page 3 of 3 cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV Office 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. Alan B. Wang MS O-7 D1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health & Human Services P.O. Box 1437 Slot H-30 Little Rock, AR 72203-1437

Attachment 1 2CAN040805 Analysis of Proposed Technical Specification Change -

Replacement Page

Attachment to 2CAN040805 Page 3 of 7 ANO-2 TS REFERENCE DESCRIPTION OF CHANGE 3.0.4 (LCO Applicability) Changed in accordance with TSTF-359.

4.0.4 (SR Applicability) Changed in accordance with TSTF-359.

3.3.3.5 (Remote Shutdown Instruments) Changed in accordance with TSTF-359.

3.3.3.6 (Post Accident Monitoring) Changed in accordance with TSTF-359.

3.4.3 (Pressurizer Safety Valves) LCO 3.0.4.c applicability is added to Action b. Currently, the Action permits suspension of LCO 3.0.4 for the purposes of testing one valve at a time upon entry into or during operation in Mode 3. The TSTF intent is to delete all exceptions to LCO 3.0.4 and apply LCO 3.0.4.c where appropriate. Therefore, the LCO 3.0.4 exception is deleted and LCO 3.0.4.c applicability is added. This is an equivalent change and is subsequently, risk neutral.

The Action wording is additionally revised in this same paragraph to clarify the LCO exemption in support of valve testing. This wording is original TS wording with the exception of the 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, which was changed from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in Amendment 36 by NRC letter dated October 19, 1982 (copy available upon request). The current wording does not clearly exempt the requirements of Action a for 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, although this was clearly the intent since Action a would only allow 15 minutes to restore valve operability, regardless of the reason for inoperability. The NRC stated in their October 19, 1982 SE that the current TS 3.4.3 Action Statement 3.4.3.b also provides for suspension of the LCO (emphasis added) for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for entry into and operations in MODE 3 to test and adjust the valves. However, LCO 3.0.4 does not permit exemption from requirements of Action Statements, as currently worded, but only permits entry into a Mode of operation while relying on Action Statements. The additional proposed change to this paragraph acts only to clarify the original intent of the Action exception. Therefore, this change is administrative in nature and involves no additional plant risk. A markup of the Bases is provided in Attachment 5, which includes additional clarification to ensure that the summed time of both valves being individually inoperable in Mode 3 does not exceed 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, consistent with the improved standard TSs of NUREG 1432, Rev. 3.1. These Bases will be revised upon approval of this amendment under the requirements of 10 CFR 50.59.

Attachment to 2CAN040805 Page 4 of 7 ANO-2 TS REFERENCE DESCRIPTION OF CHANGE 3.4.6.1 (RCS Leak Detection) Changed in accordance with TSTF-359.

3.4.8 (RCS Specific Activity) LCO 3.0.4.c applicability added in accordance with TSTF-359.

3.4.12 (Low Temperature Overpressure Changes are made consistent with TSTF-359.

Protection) 3.5.3 (ECCS Subsystem - Shutdown) Changes are made consistent with TSTF-359.

3.7.1.2 (Emergency Feedwater) Changes are made consistent with TSTF-359.

3.7.1.5 (Main Steam Isolation Valves) The STS does not contain an exemption to LCO 3.0.4 for MSIVs and, therefore, this exemption is deleted, consistent with the intent of TSTF-359.

3.7.6.1 (CREVS) Changed in accordance with TSTF-359.

3.8.1.1 (AC Sources) Changes are made consistent with TSTF-359. Note that the STS does not contain an exemption to LCO 3.0.4 for Startup Transformer #2 (see Action A.2) and, therefore, this exemption is deleted, consistent with the intent of TSTF-359.

Attachment 2 2CAN040805 Proposed Technical Specification Changes (mark-up) - Replacement Page

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system and

b. Two separate and independent diesel generators each with:

1. A day fuel tank containing a minimum volume of 300 gallons of fuel,

2. A separate fuel storage system, and

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

NOTE: Specification 3.0.4.b is not applicable to diesel generators.

a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, perform the following:

1. Demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and

2. Restore the offsite A.C. circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Startup Transformer No. 2 may be removed from service for up to 30 days as part of a preplanned preventative maintenance schedule. The 30-day allowance may be applied not more than once in a 10-year period. The provisions of Specification 3.0.4 are not applicable to Startup Transformer No. 2 during the 30-day preventative maintenance period.

ARKANSAS - UNIT 2 3/4 8-1 Amendment No. 141,215,234,249,255,

Attachment 3 2CAN040805 Revised Technical Specification Pages - Replacement Page

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system and

b. Two separate and independent diesel generators each with:

1. A day fuel tank containing a minimum volume of 300 gallons of fuel,

2. A separate fuel storage system, and

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

NOTE: Specification 3.0.4.b is not applicable to diesel generators.

a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, perform the following:

1. Demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and

2. Restore the offsite A.C. circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Startup Transformer No. 2 may be removed from service for up to 30 days as part of a preplanned preventative maintenance schedule. The 30-day allowance may be applied not more than once in a 10-year period.

ARKANSAS - UNIT 2 3/4 8-1 Amendment No. 141,215,234,249,255,

Attachment 4 2CAN040805 List of Regulatory Commitments - Replacement Page to 2CAN040805 Page 1 of 1 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.

TYPE (Check one) SCHEDULED COMPLETION COMMITMENT DATE (If Required)

ONE-TIME CONTINUING ACTION COMPLIANCE Entergy will establish the Technical To be Specification Bases for LCO 3.0.4 and implemented SR 4.0.4 as adopted with the applicable with license amendment. amendment Entergy will revise Technical Specification To be Bases for LCO 3.3.4, Pressurizer Safety implemented Valves, to ensure that the summed time of with both valves being individually inoperable in amendment Mode 3 does not exceed 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Attachment 5 2CAN040805 Proposed Technical Specification Bases Changes (mark-up) -

Replacement Page

3/4.4 REACTOR COOLANT SYSTEM BASES 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION The plant is designed to operate with both reactor coolant loops and associated reactor coolant pumps in operation, and maintain DNBR above the limits specified by Specification 3.2.4 during all normal operations and anticipated transients.

In MODE 3, a single reactor coolant loop provides sufficient heat removal capability for removing decay heat; however, single failure considerations require that two loops be OPERABLE.

In MODES 4 and 5, a single reactor coolant loop or shutdown cooling loop provides sufficient heat removal capability for removing decay heat; but single failure considerations require that at least two loops be OPERABLE. Thus, if the reactor coolant loops are not OPERABLE, this specification requires two shutdown cooling loops to be OPERABLE.

The operation of one Reactor Coolant Pump or one shutdown cooling pump provides adequate flow to ensure mixing, prevent stratification and produce gradual reactivity changes during boron concentration reductions in the Reactor Coolant System. The reactivity change rate associated with boron reductions will, therefore, be within the capability of operator recognition and control.

3/4.4.2 and 3/4.4.3 SAFETY VALVES The pressurizer code safety valves operate to prevent the RCS from being pressurized above its Safety Limit of 2750 psia. Each safety valve is designed to relieve 453,817 lbs. per hour of saturated steam at 3% overpressure. The relief capacity of a single safety valve is adequate to relieve any overpressure condition which could occur during shutdown.

Two safety valves are required in MODES 1, 2 and 3. One safety valve is required in MODE 4 with Tc > 220°F. For the remainder of MODES 4, 5 and 6 with the reactor vessel head in place, overpressure protection is provided by the operating procedures and LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System.

During operation, all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2750 psia. The combined relief capacity of these valves is sufficient to limit the Reactor Coolant System pressure to within its Safety Limit of 2750 psia following a complete loss of turbine generator load while operating at RATED THERMAL POWER and assuming no reactor trip until the first Reactor Protective System trip setpoint (Pressurizer Pressure-High) is reached (i.e., no credit is taken for a direct reactor trip on the loss of turbine) and also assuming no operation of the steam dump valves.

Demonstration of the safety valves' lift setting will occur only during shutdown and will be performed in accordance with the provisions of Section XI of the ASME Boiler and Pressure Vessel Code.

The ACTION permits the use of the provisions of LCO 3.0.4.c for entry into Mode 3 and suspension of the requirements of ACTION a to support testing of one valve at a time for up to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> per valve in Mode 3. ACTION a must be entered if either valve is removed from service for more than 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> or if the summed time in which each valve is removed from service for testing in Mode 3 exceeds 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This allowance permits entry into the applicable MODE(s) while relying on the ACTION and suspends the shutdown requirement for a limited period of time to verify proper valve settings prior to startup.

ARKANSAS - UNIT 2 B 3/4 4-1 Amendment No. 24,29,149,199 Rev. 1,10,