CNRO-2007-00039, Entergy Operations, Inc. - Pending License Amendment Requests Affected by TSTF-500

Entergy Operations, Inc. - Pending License Amendment Requests Affected by TSTF-500

ML073180400
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	11/08/2007
From:	Ford B Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2007-00039, TSTF-500
Download: ML073180400 (2)

Text

IL

-d-Enteigy Entergy Operations, Inc.

1340 Echelon Parkway Jackson, Mississippi 39213-8298 Tel 601-368-5758 Bryan S. Ford Senior Manager, Nuclear Safety &

Licensing CNRO-2007-00039 November 8, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Pending License Amendment Requests Affected by TSTF-500 River Bend Station Grand Gulf Nuclear Station Docket No. 50-458 Docket No. 50-416 License No. NPF-47 License No. NPF-29 Arkansas Nuclear One Waterford 3 Steam Electric Units 1 & 2 Station Docket Nos. 50-313 & 50-368 Docket No. 50-382 License Nos. DPR-51 & NPF-6 License No. NPF-38

Reference:

Letter TSTF-07-26 from the Technical Specification Task Force to the USNRC, "TSTF-500, Revision 0, "DC Electrical Rewrite - Update to TSTF-360," dated August 31, 2007.

Dear Sir or Madam:

This letter is to inform you of Entergy's plans to submit License Amendment Requests (LARs) to correct non-conservative Technical Specification (TS) Surveillance Requirements (SRs) related to certain battery performance criteria. Specifically, Entergy was informed through operating experience information and NRC inspections that at some plants the SR criteria for battery inter-cell connection resistances and at Arkansas Nuclear One, battery terminal voltage, may not be sufficient to verify the design basis of the batteries. Condition reports have been written for affected plants and actions have been taken to impose administrative controls that maintain more restrictive limits that are sufficient to ensure battery operability.

The Entergy plants affected are Arkansas Nuclear One, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station.

Entergy recognizes the need to submit LARs to correct the TS discrepancy as discussed in NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety." However, it would be premature and inefficient to propose any TS changes at this time because changes to the affected SRs have been A bef

CNRO-2007-00039 Page 2 of 3 proposed by TSTF-500 (referenced above) and TSTF-500 remains under NRC staff review.

Therefore, LARs to resolve the TS discrepancy are scheduled to be submitted after completion of the NRC review of TSTF-500. Should TSTF-500 be rejected or revised, Entergy will adjust LAR plans accordingly.

NRC Administrative Letter 98-10 states in part:

In summary, the discovery of an improper or inadequate TS value or required action is considered a degraded or nonconforming condition as defined in GL 91-18. Imposing administrative controls in response to an improper or inadequate TS is considered an acceptable short-term corrective action. The staff expects that, following the imposition of administrative controls, an amendment to the TS, with appropriate justification and schedule, will be submitted in a timely fashion.

Administrative controls have b~een implemented as discussed above. TSTF-500, as currently written, proposes to relocate the battery resistance surveillances and the terminal voltage to a licensee controlled program. It also requires licensees to address the resistance limit issue by providing a basis for the licensee's resistance limits. Entergy believes that the TSTF proposed change is the best approach for resolution of the TS discrepancy and plans to submit LARs based on this approach.

If you have any questions or require additional information, please contact Ron Byrd at (601) 368- 5792.

This letter contains no new commitments.

Sincerely, BSF/RWB/baa cc: Mr. W. R. Brian (GGNS)

Mr. T. A. Burke (ECH)

Mr. J. S. Forbes (ECH)

Mr. J. T. Herron (ECH)

Mr. T. G. Mitchell (ANO)

Mr. N. S. Reynolds (W&S)

Mr. L. J. Smith (Wise, Carter)

Mr. J. E. Venable (RBS)

Mr. K. T. Walsh (W-3)

• Mr. Elmo E. Collins, Regional Administrator, RIV Mr. N. Kalyanam, Project Manager, W-3 Mr. A. B. Wang, Project Manager, ANO Mr. B. K. Vaidya, Project Manager, GGNS, RBS