2CAN041401, License Amendment Request - Withdrawal Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286 and TSTF-471

License Amendment Request - Withdrawal Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286 and TSTF-471

ML14113A604
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/23/2014
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN041401, TAC ME8348
Download: ML14113A604 (7)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President - Operations Arkansas Nuclear One 2CAN041401 April 23, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request - Withdrawal Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Entergy letter dated April 4, 2012, License Amendment Request -

Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (2CAN041201) (ML12096A022) (TAC No. ME8348)

2. NRC email dated May 10, 2012, Proposed License Amendment Request to Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (ML121310562)

3. Entergy letter dated July 9, 2012, License Amendment Request -

Supplemental - Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (2CAN071201) (ML12192A089)

Dear Sir or Madam:

With regard to Reference 1, Entergy Operations, Inc. (Entergy) submitted a request to amend the Technical Specifications (TSs) for Arkansas Nuclear One, Unit 2 (ANO-2) related to a revised fuel assembly drop analysis and adoption of NRC-approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Travelers TSTF-51, TSTF-272, TSTF-286, and TSTF-471. By email dated May 10, 2012 (Reference 2), the NRC accepted the proposed amendment for review and notified Entergy of supplemental information that would be necessary for the NRC to complete the overall review of the Reference 1 submittal. Entergy submitted the requested supplemental information in letter dated July 9, 2012 (Reference 3).

2CAN041401 Page 2 of 3 Recent contact with the NRC Staff has indicated that the NRC cannot complete the review of the requested change. This has resulted in a decision by Entergy to withdraw the subject amendment request. Entergy is disappointed that the NRC cannot complete the review considering the last Request for Additional Information was responded to in June 2013 and considering ANO has expended more than $240,000.00 in NRC review fees associated with the amendment request to date.

Entergy does understand the NRC staff has some open concerns noted in a letter to the TSTF.

These concerns were slanted toward generic application of the TSTFs to all plant types. ANO had provided significant detail to address these concerns. A brief history of the amendment request is attached.

To date, no additional RAIs have been issued to ANO in relation to the subject amendment request. Absent adoption of the subject TSTFs, ANOs ability to gain the intended operational flexibility which has previously been approved by the NRC for other plants cannot be realized.

Regardless, significant delays and costs will be realized with regard to resolving the non-conservative TSs involved.

Notwithstanding the above, Entergy requests the subject letters be withdrawn from further NRC review. Any commitments contained with correspondence directly related to the subject amendment request are also withdrawn. There are no new commitments contained 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 April 23, 2014.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWNING JGB/dbb

Attachment:

Historical Timeline of Entergy Letter Dated April 4, 2012 License Amendment Request - Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471

2CAN041401 Page 3 of 3 cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Peter Bamford MS O-8B3 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 to 2CAN041401 HISTORICAL TIMELINE OF ENTERGY LETTER DATED APRIL 4, 2012 License Amendment Request - Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471

Attachment to 2CAN041401 Page 1 of 3 Historical Timeline of Entergy Letter Dated April 4, 2012 License Amendment Request - Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 The approximate time since original submittal is also included.

Date Subject Because the proposed ANO submittal would address non-conservative TSs and adopt previously NRC-approved TSTFs October 5, 2011 associated with these TSs, a pre-submittal meeting between ANO and NRR personnel was held at NRR headquarters. NRC comments were addressed in ANOs original submittal (Reference 1).

April 4, 2012 Amendment request submitted (Reference 1) (T = 0)

Supplemented the amendment request to more fully adopt TSTF-51 at July 12, 2012 NRC request. (T + 3 months)

By email, the NRC identified minor changes needed to complete the review process. The NRC also requested that all of Attachment 1 of the Reference 3 letter be resubmitted and all the TS pages be June 12, 2013 resubmitted, in order for this final supplement to represent a complete package. Entergy submitted the requested supplemental information in letter dated June 18, 2013 (Reference 5). (T + 1 year, 2 months)

Response to June 12, 2013, RAIs submitted (Reference 5).

June 18, 2013 (T + 1 year, 2 months)

During subsequent review of Attachment 2 of the Reference 5 supplemental letter, an error was discovered on the markup of TS page 3/4 3-25 in that the markup page did not exactly match the corresponding clean (revised) TS page (Attachment 3 of the July 1, 2013 Reference 5 letter), nor did it match the corresponding discussion and illustration included on Pages 23 and 24, respectively, of Attachment 1 of the Reference 5 letter. This was corrected in the Reference 6 letter.

(T + 1 year, 3 months)

The TSTF (represented by Excel Services Corporation) was notified August 28, 2013 by the NRC may no longer support TSTF-471. (T + 1 year, 4 months)

ANO notified the NRC that a possible solution to any concerns which ANO could promptly support may be to replace the core alterations August 28, 2013 terms with a requirement to cease the movement of fuel. (T + 1 year, 4 months)

NRC issues formal letter to TSTF stating concerns and requesting November 7, 2013 response (ML13246A358). (T + 1 year, 7 months)

Attachment to 2CAN041401 Page 2 of 3 Date Subject ANO completes industry email survey to verify that fuel assembly loading errors have not historically been identified by source range detectors (loading errors are detected by core mapping or during low November 22, 2013 power physics testing). Although a majority of plants did not respond, those responding indicated loading errors have not been known to be identified via use of source range detectors. (T + 1 year, 7 months)

Call between Excel, TSTF, NRC TS Branch, Palo Verde, and ANO.

December 11, 2013 TSTF plans to present a draft response during the upcoming January NRC/TSTF meeting. (T + 1 year, 8 months)

Excel notified by NRC that NRC plans on rejecting the ANO and Palo Verde submittals, because the letters specifically request adoption of December 19, 2013 the subject TSTFs by name, which the NRC no longer fully supports, until issues resolved. (T + 1 year, 8 months)

Draft response to generic NRC concerns with the subject TSTFs (sent January 8, 2014 by Excel) discussed in TSTF/NRC meeting held in Rockville, MD.

(T + 1 year, 9 months)

ANO call with NRC TS Branch (including the ANO - NRR Plant Licensing Branch IV-1 Chief) and other branch reviewers that have potential concerns with one or more of the subject TSTFs. Following discussion, all agreed that ANO may be able to resolve issue on plant February 3, 2014 specific bases by specifically identifying and addressing NRC concerns in any future supplement. NRC took action to review ANO submittals in detail (the ANO submittals already contained supporting detail well above that supporting the original TSTFs) and determine if more information would be required. (T + 1 year, 10 months)

ANO notified by NRR PM that not all reviewers had determined whether additional questions would be warranted and, therefore, there February 25, 2014 may not be sufficient time to proceed prior to the amendment request reaching 2 years of age. (T + 1 year, 10 months)

NRC provided via email draft questions. ANO provided informal response via email with significant detail and content the same day as February 27, 2014 a means of verifying that the questions were clearly understood by the licensee. No response was received. (T + 1 year, 10 months)

Attachment to 2CAN041401 Page 3 of 3

REFERENCES:

1. Entergy letter dated April 4, 2012, License Amendment Request - Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (2CAN041201) (ML12096A022) (TAC No. ME8348)

2. NRC email dated May 10, 2012, Proposed License Amendment Request to Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (ML121310562)

3. Entergy letter dated July 9, 2012, License Amendment Request - Supplemental - Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (2CAN071201) (ML12192A089)

4. NRC email dated June 12, 2013, Request for Additional Information - Proposed License Amendment Request to Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (ML13164A031)

5. Entergy letter dated June 18, 2013, License Amendment Request - Supplemental -

Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (2CAN061302)

(ML13170A197)

6. Entergy letter dated July 1, 2013, License Amendment Request - Supplemental - Technical Specification (TS) Change Related to Revised Fuel Assembly Drop Analysis and Adoption of TSTF-51, TSTF-272, TSTF-286, and TSTF-471 (2CAN071301) (ML13183A124)