ML021140074
| ML021140074 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/25/2002 |
| From: | Jaffe D NRC/NRR/DLPM |
| To: | Millar D Entergy Operations |
| References | |
| Download: ML021140074 (23) | |
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Questions on Revision to Section 6.0 3/25/02 10:06AM David Jaffe DHJ@nrc.gov Recipients entergy.com DMILLAR (DMILLAR@entergy.com)
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David Jaffe - Questions on Revision to Section 6.0 Page 1 From:
David Jaffe To:
DMILLAR@entergy.com Date:
3/25/02 10:06AM
Subject:
Questions on Revision to Section 6.0 Per our discussion, attached are the Questions which I will also send you via letter. Please call me when you are ready to discuss.
David Jaffe - Arkansasrai.wpd Page 1 Arkansas Nuclear One - Unit 2 Request for Additional Information 1.0 General and License Conditions 1.0-1 All Sections of Proposed Technical Specifications (PTS)
The January 31, 2002, amendment request for Arkansas Nuclear One - Unit 2 (ANO-2) provided justifications for converting from the current Unit 2 Technical Specifications (2 CTS) to the PTS. A number of these justifications provide a general description of the change and concludes that the change is acceptable because it is consistent with the Arkansas Nuclear One - Unit 1 (ANO-1) Improved Technical Specifications (ITS) and/or NUREG-1432, "Standard Technical Specifications-Combustion Engineering Plants" (STS). Consistency with the ITS or STS is not an adequate justification for concluding a change is acceptable. In converting the ANO-1 current Technical Specifications (1CTS) to the ITS, changes to the 1 CTS were classified as Administrative (A), More Restrictive (M), Less Restrictive (L) and Less Restrictive - Administrative Deletion of Requirements (LA), and justified accordingly (DOC). This has not been done for the ANO-2 changes.
In addition, when the ITS deviated from the STS, an appropriate discussion and justification (JFD) was provided. This also was not done and needs to be provided to show why the deviation from the STS is applicable to the PTS. All changes from the 2CTS to the PTS including deviations from the STS need to be justified. As a minimum, if a similar change was made in converting 1 CTS to the ITS, was justified by an acceptable "DOC" or "JFD", and is applicable to ANO-2, then only the special DOC/JFD's need to be referenced. This also applies to any changes made as a result of TSTF's (i.e., TSTF-287). Comment: Revise the discussions and justifications for all the changes in light of the above discussion.
ANO-2 Response:
1.0-2 License Condition (LC) 2.C.(6) for ANO-1 (CTS)
LC 2.C.(3)(p)
LC 2.C.(5)
LC 2.C.(6)
ITS 5.5.3 PTS 6.5.2 PTS 6.5.10 ANO-2 LC 2.C.(3)(p) and 2.C.(5) have been relocated to the Administrative Control section as programs in PTS 6.5.10 and 6.5.2 respectively. This relocation is acceptable (See Comment Numbers 6.0-1, 6.0-15, and 6.0-19 for additional concerns with the programs); however, LC 2.C.(6) was not relocated. ANO-1 LC 2.C.(6) is the same license condition as ANO-2 LC 2.C.(6). In the conversion of 1 CTS to the ITS, LC 2.C.(6) became ITS 5.5.3 "Post Accident Sampling." If the intent of the amendment is to make PTS 6.0 consistent with ITS 5.0, then this license condition should also have been relocated to PTS 6.5. Comment: Revise the licensee conditions and PTS to relocate 1
Page 2 LC2.C.(6) to PTS 6.5 and provide the appropriate discussions and justifications.
ANO-2 Response:
3/4.3 Instrumentation 3/4.3-1 DOC M.4 1CTS Table 3.5.1-1 Items 17 and 18 2CTS Table 3.3-6 Actions 17 and 20 ITS 3.3.16 Action C PTS Table 3.3-6 Actions 17 and 20 2CTS Table 3.3-6 Actions 17 and 20 specify the remedial actions to be taken for inoperable Control Room Ventilation Intake Duct Monitors. If the remedial actions cannot be met, then 2CTS 3.0.3 must be entered, which requires the unit be in Cold Shutdown within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. PTS Table 3.3-6 Actions 17 and 20 require that if the initial remedial actions cannot be met, the unit must be in Cold Shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The justification for the proposed changes states that the proposed change "is consistent with the current requirement to enter TS 3.0.3... and therefore is not considered a technical change." The staff disagrees with the justification that there is no technical change. The staff considers the change to be a More Restrictive change (37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />). A similar change was made in the ANO-1 conversion, was classified as a More Restrictive change, and was discussed in DOC M.4. See Comment Number 1.0-1. Comment:
Provide a discussion and justification for the More Restrictive change. See Comment Number 1.0-1.
ANO-2 Response 3/4.3-2 DOC M.4 1CTS Table 3.5.1-1 Item 18 2CTS Table 3.3-6 Action 20 ITS 3.3.16 Action A PTS Table 3.3-6 Action 20 2CTS Table 3.3-6 Action 20 specifies that if the inoperable channel cannot be restored to OPERABLE status within 7 days, then within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the Control Room Emergency Ventilation System shall be placed in the re-circulation mode of operation.
The PTS deletes the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance and requires that the channel be restored to OPERABLE status or the Control Room Emergency Ventilation System be placed in the re-circulation mode of operation within 7 days. No justification is provided for this More Restrictive change other than consistency with the ITS. A similar change was made in the ANO-1 conversion, was classified as More Restrictive and discussed in DOC M.5.
See Comment Number 1.0-1. Comment: Provide a discussion and justification for this 2
David Jaffe - Arkansasrai.wpd
David Jaffe - Arkansasrai.wpd More Restrictive change. See Comment Number 1.0-1.
ANO-2 Response:
3/4.3-3 DOC L.13 lCTS Table 4.1-1 Item 28.b ITS SR 3.3.16.2 lCTS Table 4.1-1 Item 28.b specifies the surveillance requirements for the Control Room Emergency Ventilation System radiation instrumentation. In converting lCTS to the ITS, two changes were made to the monthly channel functional test - the deletion of the check of the self checking feature on each detector and the adding of the ITS SR Note which provides a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time period for performing the SR without entering the associated Actions. These changes were classified as Less Restrictive (L) and discussed DOC L.13. It is assumed that the 2CTS surveillance is similar to 1CTS.
Nothing in the amendment package discusses the instrumentation SR for ANO-2. For consistency, the ANO-2 SRs need to be consistent with the ITS. Comment: Verify that the ANO-2 Control Room Emergency Ventilation System Instrumentation SR is consistent with the ITS. If they are not, revised it and provide a discussion and justification for this Less Restrictive (L) change. See Comment Number 1.0-1.
ANO-2 Response:
3/4.3-4 2CTS Table 3.3-6 Actions 18 and 19 2CTS Table 3.3-10 Actions 3:b and 4:b PTS Table 3.3-6 Actions 18 and 19 PTS Table 3.3-10 Actions 3:b and 4:b See Comment Number 6.0-29 Comment: See Comment Number 6.0-29 ANO-2 Response:
3/4.5 Emergency Core Cooling Systems 3/4.5-1 2CTS 3.5.2 Action b 2CTS 3.5.3 Action b PTS 3.5.2 Action b PTS 3.5.2 Action b See Comment Number 6.0-29. Comment: See Comment Number 6.0-29.
ANO-2 Responses 3
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David Jaffe - Arkansasrailwpd 3/4.7 Plant Systems 3/4.7-1 DOC L.20 lCTS 3.9.2 2CTS 3.7.6.1 and Actions ITS LCO 3.7.9 Note 1, Actions B, C, and F, and Associated Bases PTS 3.7.6.1, Action d, and Associated Bases During the ANO-1 conversion review, lCTS 3.9.2/ITS 3.7.9 was modified by TSTF -287 Revision 5. This change added ITS LCO 3.7.9 Note 1 and ITS 3.7.9 Action B, modified ITS 3.7.9 Action F and revised certain areas of ITS 3.7.9 Bases. These Less Restrictive (L) changes were discussed in DOC L.20. PTS 3.7.6.1 only adds Action d which corresponds to ITS 3.7.9 Actions B and C. ITS 3.7.9 Note 1 and the associated TSTF-287 Bases changes were not added. ITS 3.7.9 Action F is implied by the structure and format of the 2CTS/PTS. The PTS is not consistent with the ITS, as stated in the PTS justifications and no justification is provided for this Less Restrictive (L) change. No justification is provided as to why these changes were not included in the PTS and associated Bases (See Comment Number 1.0-1). ITS LCO 3.7.9 Note 1 is needed to avoid entry into the Action statements when the control room boundary is intermittently opened (i.e., entry and exit). The 2CTS/PTS would require entry into the actions under these circumstances. In addition, TSTF-287 was approved based on the changes made to the STS Bases, and that those changes were required in order to use TSTF-287 to be in the plant specific Bases because of certain commitments and guidelines contained in those Bases discussions. No justification is provided as to why these changes were not included in the PTS and associated Bases. Comment: Revise PTS 3.7.6.1 and its associated Bases to be consistent with ITS 3.7.9/TSTF-287. Provide an appropriate discussion and justification for this Less Restrictive (L) change. See Comment Number 1.0-1.
ANO-2 Response:
3/4.7-2 DOC A.16 I CTS 3.9.2 2CTS 3.7.6.1 ITS LCO 3.7.9 Note 2 PTS 3.7.6.1 During the ANO-1 conversion review, 1CTS 3.9.2/ITS 3.7.9 was modified by the addition of ITS LCO 3.7.9 Note 2, which states that "One CREVS train shall be capable of automatic actuation." This Administrative change was discussed in DOC A.16. 2CTS 3.7.6.1/PTS 3.7.6.1 does not have this Note. Thus the PTS is not consistent with the ITS, and would require both CREVS trains to be capable of automatic actuation. No justification is provided as to why this Note was not included in the PTS. Comment:
4 Page 4
David Jaffe - Arkansasrai.wpd Revise the PTS to include this Note and provide an appropriate discussion and justification for this Administrative change. See Comment Number 1.0-1.
ANO-2 Response:
3/4.7-3 DOC LA.1 1CTS 4.10.1.a and 4.10.2.a 2CTS 4.7.6.1.1.a and 4.7.6.1.2.a ITS SR 3.7.9.1, SR 3.7.10.1 and Associated Bases PTS 4.7.6.1.1.a and 4.7.6.1.2.a 2CTS 4.7.6.1.l.a and 4.7.6.1.2.a have the following surveillance frequency: "At least once per 31 days on a STAGGERED TEST BASIS..." The corresponding surveillances in 1CTS are 1CTS 4.10.1.a and 4.10.2.a, respectively, had the same frequency. In converting 1CTS 4.10.1.a and 4.10.2.a to ITS SR 3.7.10.1 and SR 3.7.9.1 respectively, the phrase "STAGGERED TEST BASIS" was relocated to the associated Bases. This Less Restrictive (LA) change was discussed in DOC LA.l. PTS 4.7.6.1.1.a and 4.7.6.1.2.a are not consistent with the ITS, since it would require an amendment change to modify the "STAGGERED TEST BASIS" frequency in the PTS, but not in the ITS.
However, a mistake was made during the conversion in allowing the relocation of the requirement to stagger the test frequency. The format and structure of the ITS/STS does not allow the Bases to dictate requirements, particular frequency requirements. The ITS frequency should have been "15 days on a STAGGERED TEST BASIS" or just 31 days since a staggered test basis does not provide any additional safety or improve system operability.
Comment: Provide a discussion and justification for this inconsistency/discrepancy.
ANO-2 Response:
3/4.7-4 DOC LA.1 ICTS 4.10.2.a and 4.10.2.d.2 2CTS 4.7.6.1.2.a and 4.7.6.1.2.d.2 ITS SR 3.7.9.1, SR 3.7.9.3 and Associated Bases PTS 4.7.6.1.2.a, 4.7.6.1.2.b and Associated Bases 2CTS 4.7.6.1.2.a/PTS 4.7.6.1.2.a states the following: "At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes." 2CTS 4.7.6.1.2.d.2/PTS 4.7.6.1.2.b states the following: "At least once per 18 months by verifying that on a control room high radiation test signal, the system automatically isolates the control room within 10 seconds and switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks." ICTS 4.10.2.a and 4.10.2.d.2 used the exact same words, respectively; however, during the conversion of 1CTS 4.10.2.a and 4.10.2.d.2 to ITS SR 3.7.9.1 and 5
Page 5
SR 3.7.9.3 respectively, certain details were relocated to the ITS Bases. These Less Restrictive (LA) changes were discussed in DOC LA.1. In ICTS 4.10.2.a the relocated words were "initiating from the control room, flow through the HEPA filters and charcoal adsorbers." In iCTS 4.10.2.d.2 the relocated words were "within 10 seconds" and "with flow through the HEPA filters and charcoal adsorber banks." By retaining these words in PTS 4.7.6.1.2.a and 4.7.6.1.2.b, it makes them TS requirements and would require an amendment to change them where as in the ITS they are Bases details which may be changed without an amendment request. Also, the PTS surveillances are not consistent word wise with the corresponding ITS surveillances. Comment: Revise the PTS surveillances and Bases to be consistent with the ITS Srs and Bases and provide the appropriate discussions and justifications for these Less Restrictive (LA) changes. See Comment Number 1.0.-1.
ANO-2 Response:
3/4.7-5 DOC L.16 1CTS 4.10.2.d.2 2CTS 4.7.6.1.2.d.2 ITS SR 3.7.9.3 PTS 4.7.6.1.2.b 2CTS 4.7.6.1.2.d.2/PTS 4.7.6.1.2.b states the following: "At least once per 18 months by verifying that on a control room high radiation test signal..." iCTS 4.10.2.d.2 used the exact same words; however, during the conversion of 1CTS 4.10.2.d.2 to ITS SR 3.7.9.3 the words "on a control room high radiation test signal" were changed to "on an actual or simulated actuation signal." This Less Restrictive (L) change was discussed in DOC L.16 and was made to allow actual actuation signals to be used to satisfy surveillance requirements. Since PTS 4.7.6.1.2.b does not allow actual signals to be used ITS SR 3.7.9.3 would only be allowed to used the simulated or test signal. Thus, PTS 4.7.6.1.2.b is not consistent with the ITS. Comment: Revise PTS 4.7.6.1.2.b to be consistent with ITS SR 3.7.9.3 and provide the appropriate discussion and justification for this Less Restrictive (L) change. See Comment Number 1.0-1.
ANO-2 Response:
3/4.7-6 DOC M.29 1CTS 4.10.2 ITS SR 3.7.9.4 PTS 4.7.6.1 In converting 1CTS 4.10.2 to ITS 3.7.9, a new surveillance (ITS SR 3.7.9.4) was added.
This change was considered as a More Restrictive change and was discussed in DOC M.29. PTS 4.7.6.1 does not contain a similar surveillance which makes it inconsistent with ITS 3.7.9, and could result in TS interpretation problems, particular on unit shutdown 6
SDavid Jaffe - Arkansasrai~wpd Page 6
David Jaffe - Arkansasrai.wpd Page 7 requirements. No justification is provided to show why PTS 4.7.6.1 should not be consistent with ITS SR 3.7.9.4. Comment: Revise PTS 4.7.6.1 to include ITS SR 3.7.9.4 and provide the appropriate discussion and justification for this More Restrictive change. See Comment Number 1.0.-I.
ANO-2 Response:
3/4.7-7 2CTS 3.7.12 Action a PTS 3.7.12 Action a See Comment Number 6.0-29. Comment: See Comment Number 6.0-29.
ANO-2 Response:
3/4.8 Electric Power Systems 3/4.8-1 2CTS 3.8.1.1 Actions, 4.8.1.1.2.a.2 and 4.8.1.1.2.b ITS 3.8.3 ACTIONS A, B, C and E, and SRs 3.8.3.1 and 3.8.3.2 PTS 3.8.1.1 Actions, 4.8.1.1.2.a.2, 4.8.1.1.2.b, and 6.5.13 The amendment package relocates 2CTS 4.8.1.1.2.b to the Administrative Controls Section (2CTS/PTS 6.0) and makes it into a program (PTS 6.5.13). While the relocation to PTS 6.5.13 is acceptable (See Comment Numbers 6.0-1 and 6.0-22 for additional concerns on the program itself), some areas of concern arise with regard to 2CTS 3/4.8.1.1 and ITS 3.8.3 consistency. It is unclear if the fuel oil storage tank for ANO-2 is the same tank used for ANO-1 or if they are interconnected. If this is the case, then failure to meet PTS 4.8.1.1.2.a.2/ITS SR 3.8.3.1 and/or PTS 4.8.1.1.2.b/ITS SR 3.8.3.2 results in different actions being taken for ANO-1 and ANO-2. Comment: Clarify if the tanks are the same, different or interconnected. If they are the same and/or interconnected, revise the PTS to be consistent with the ITS ACTIONS for fuel oil limits and tanks. Provide the appropriate discussions and justifications for this change. See Comment Numbers 1.0-1, 6.0-1 and 6.0-22.
ANO-2 Response:
6.0 Administrative Controls 6.0-1 See Table 1, page 21 In the 2CTS License Conditions (LC) and 6.0 specifications cited in Table 1, the wording is either exactly the same as or similar to the corresponding 1 CTS License Conditions and 6.0 specifications in cited Table 1. In converting 1 CTS to the ITS, some of these 7
David Jaffe - Arkansasrai.wpd Page 8 LC/specifications were modified and justified by the appropriate DOCs/JFD and others were not modified. Yet for the PTS 6.0 specifications (cited in Table 1), the wording is different from the corresponding ITS 5.0 specification. No justification is provided to describe or justify these differences/inconsistencies. Any justifications that were provided for these changes only stated that the ITS and PTS were consistent. If the intent of the amendment is to make the Unit 2 TS consistent with the Unit 1 ITS, then the wording for similar specifications in PTS 6.0 should be the same as the corresponding ITS 5.0 specification. The following Comment Numbers specify the specifics, as well as the appropriate DOCs/JFDs for each specification: 6.0-2, 6.0-3, 6.0-4, 6.0-7, 6.0-9, 6.0-11, 6.0-12, 6.0-13, 6.0-14, 6.0-15, 6.0-16, 6.0-17, 6.0-19, 6.0-20, 6.0-22, 6.0-25 and 6.0-26. Comment: Either make the PTS consistent with the ITS or provide a discussion and justification for the deviation/inconsistency. See Comment Number 1.0-1.
ANO-2 Response:
6.0-2 JFD 1 ICTS 6.1.1 and 6.2.1.b 2CTS 6.1.1 and 6.2.1.b ITS 5.1.1 and 5.2.1.b PTS 6.1.1 and 6.2.1.b In converting 1CTS 6.1.1 and 6.2.1.b to ITS 5.1.1 and 5.2.1.b respectively, the words "ANO-1 plant manager" were retained. 2CTS 6.1.1 and 6.2.1.b use the same words as the respective ICTS/ITS specifications except "ANO-1 plant manager" is "ANO-2 plant manager." However, PTS 6.1.1 changes "ANO-2 plant manager" to "plant manager operations." No justification is provided for this change. See Comment Number 6.0-1.
Comment: See Comment Number 6.0-1.
ANO-2 Response:
6.0-3 JFD 29 lCTS 6.1.2 2CTS 6.1.2 ITS 5.1.2 PTS 6.1.2 1CTS 6.1.2, 2CTS 6.1.2 and PTS 6.1.2 all state the following: "...an active SRO license or...". However, ITS 5.1.2 deletes the word "license". Comment: See Comment Number 6.0-1.
ANO-2 Response:
8
David Jaffe - Arkansasrai.wpd Page 9 6.0-4 1CTS 6.2.1 and 6.2.1.c 2CTS 6.2.1 and 6.2.1.c ITS 5.2.1 and 5.2.1.c PTS 6.2.1 and 6.2.1.c lCTS 6.2.1 and 6.2.1.c, 2CTS 6.2.1 and 6.2.1.c, and PTS 6.2.1 and 6.2.1.c all use the exact same words to describe the onsite and offsite organizations. However, in converting ICTS to the ITS the word "plant" in lCTS 6.2.1 is changed to "unit" and an "and" is added after the last sentence in 1CTS 6.2.1.c. No such changes are made in the PTS. Comment: See Comment Number 6.0-1.
ANO-2 Response:
6.0-5 JFD2 1CTS Table 6.2-1 2CTS Table 6.2-1 ITS 5.2.2.a PTS 6.2.2.a STS 5.2.2.a In converting lCTS Table 6.2-1 to ITS 5.2.2.a, the licensee deviated from STS 5.2.2.a.
This deviation was justified by JFD 2. In converting 2CTS Table 6.2-1 to PTS 6.2.2.a the same deviation from the STS was used. No justification was provided for this change.
See Comment Number 1.0-1. Comment: Provide a discussion and justification for this deviation from the STS. See Comment Number 1.0-1.
ANO-2 Response:
6.0-6 JFD 2 1CTS Table 6.2-1 Note #
2CTS Table 6.2-1 Note #
ITS 5.2.2.c PTS 6.2.2.c STS 5.2.2.c In converting 1CTS Table 6.2-1 Note # to ITS 5.2.2.c, the licensee deviated from STS 5.2.2.c by adding the words "for one unit, one control room." This deviation was justified by JFD 2. In converting 2CTS Table 6.2-1 Note # to PTS 6.2.2.c the same deviation from the STS was used. No justification was provided for this change. See Comment Number 1.0-1 and 6.0-7. Comment: Provide a discussion and justification for this deviation from the STS. See Comment Numbers 1.0-1, and 6.0-7.
9
David Jaffe
- Arkansasrai.wpd Page 10 ANO-2 Response:
6.0-7 1CTS Table 6.2-1 Note#
2CTS Table 6.2-1 Note #
ITS 5.2.2.c PTS 6.2.2.c 2CTS Table 6.2-1 Note # uses the exact same words as lCTS 6.2-1 Note #. In converting 1CTS 6.2-1 Note # to ITS 5.2.2.c. The Licensee used the STS words except for the deviation discussed in Comment Number 6.0-6. In converting 2CTS Table 6.2-1 Note # to PTS 6.2.2.c the following STS/ITS words were omitted: "Members provided immediate action is taken to restore the shift crew" between "on-duty shift crew" and "composition." No justification was provided for this inconsistency. Comment: See Comment Number 6.0-1.
ANO-2 Response:
6.0-8 JFD33 1CTS Table 6.2-1 Note 5 2CTS 6.2.2.f ITS 5.2.2.g PTS 6.2.2.g 2CTS 6.2.2.f uses virtually the same words as 1CTS Table 6.2-1 Note 5. In converting 1CTS Table 6.2-1 Note 5 to ITS 5.2.2.g the phrase "unit operations shift supervisor" was changed to "operations shift crew". This change was justified by JFD 33. The same change was made in converting 2CTS 6.2.2.f to PTS 6.2.2.g; however, no justification was provided for this change. See Comment Number 1.0-1. Comment: Provide a discussion and justification for this change. See Comment Number 1.0-1.
ANO-2 Response:
6.0-9 1CTS 6.3.1 2CTS 6.3.1 ITS 5.3.1 PTS 6.3.1 1CTS 6.3.1 and 2CTS 6.3.1 have the exact same words except that 2CTS 6.3.1 has
"(1)" between "except for" and "the designated". ITS 5.3.1 and PTS 6.3.1 also have the same words except for the "(1)" in PTS 6.3.1. The "(1)" does not seem to serve a purpose and it makes the ITS and PTS inconsistent. Comment: See Comment Number 6.0-1.
10 iDavid Jaffe - Arkansasrai.wpd Page 10
David Jaffe - Arkansasrai.wpd Page 11 ANO-2 Response:
6.0-10 DOC M.3 JFD 3 1CTS 6.8.1 2CTS 6.8.1 ITS 5.4.1.b and 5.4.1.d PTS 6.4.1.b and 6.4.1.d.
STS 5.4.1. b In converting 1CTS 6.8.1 to the ITS, two new specifications were added - ITS 5.4.1.b and 5.4.1.d. These additions were justified by DOC M.3. In addition, ITS 5.4.1.b deviates from the STS by adding "Section 7.1" to clarify the appropriate section in the referenced generic letter. In converting 2CTS 6.8.1 to the PTS, the same two new specifications were added - PTS 6.4.1.b and 6.4.1.d. No justifications were provided for this More Restrictive change and the deviation from the STS. See Comment Number 1.0-1.
Comment: Provide a discussion and justification for these More Restrictive changes and deviations from the STS. See Comment Number 1.0-1.
ANO-2 Response:
6.0-11 ITS 5.4.1.c and 5.4.1.d PTS 6.4.1.d and 6.4.1.e STS 5.4.1.c and 5.4.1.d ITS/STS 5.4.1.c and 5.4.1.d has an ";and" at the end of ITS/STS 5.4.1.c. For consistency, there should be an"; and" between PTS 6.4.1.d and 6.4.1.e. Comment:
See Comment Number 6.0-1.
ANO-2 Response:
6.0-12 2CTS 6.8.4 ITS 5.5 PTS 6.5 In converting 1CTS to the ITS, a new section (ITS 5.5) was developed to contain the descriptions of all programs and manuals. ITS 5.5 states the following: "The following programs shall be established, implemented, and maintained." 2CTS 6.8.4 has the same above statement as ITS 5.5; yet in converting to PTS 6.5 this statement is deleted.
No justification is provided for this deletion/inconsistency. Comment: See Comment Number 6.0-1.
11 David J-affe - Arkansasrai.wpd Page 11
David Jaffe - Arkansasrai.wpd Page 12 ANO-2 Response:
6.0-13 DOC LA.1 JFD 1 lCTS 6.14.b 2CTS 6.14.b ITS 5.5.1.b PTS 6.5.1.b lCTS 6.14.b and 2CTS 6.14.b both use the same exact words. In converting 1CTS 6.14.b/2CTS 6.14.b to ITS 5.5.1/PTS 6.5.1 the words "General Manager, Plant Operations" are modified to "ANO general manager" in ITS 5.5.1 and "ANO General Manager" in PTS 6.5.1. The change in converting 1CTS to ITS was justified by DOC LA. 1 and JFD I. No justification was provided for the change in converting 2CTS to PTS.
In addition, no justification is provided for the inconsistency between the ITS and PTS with regard to the capitalization of the title. See Comment Numbers 1.0-1 and 6.0-1.
Comment: Provide a discussion and justification for this Less Restrictive (LA) change.
See Comment Numbers 1.0-1 and 6.0-1.
ANO-2 Response:
6.0-14 1CTS 6.14 2CTS 6.14 ITS 5.5.1 PTS 6.5.1 In converting 1CTS 6.14 to ITS 5.5.1, the word "and" was added after the first paragraph and at the end of 1CTS 6.14.a.1/ITS 5.5.1.a.1. No such change was made to PTS 5.5.1.
Comment: See Comment Number 6.0-1.
ANO-2 Response:
6.0-15 JFD40 Unit 1 LC2.C.(5)
Unit 2 LC2.C.(5)
ITS 5.5.2 PTS 6.5.2 Unit I LC2.C.(5) and Unit 2 LC 2.C.(5) use the exact same words. In converting Unit 1 LC2.C.(5) to ITS 5.5.2, the following changes were made: 1) "EOI shall...
reduce leakage from systems" was changed to "This program...those portions of systems", 2) "that would or could contain" was changed to "that could contain";
12 iDavid Jaffe - Arkansasrai.wpd Page 12
David Jaffe - Arkansasrai.wpd 3)The words "Provisions establishing" were deleted from item a., 4) "at a frequency.. cycle intervals" was changed to "at least once per 18 months.", and
- 5) The words "The provisions of SR 3.0.2 are applicable." were added. Item 5 above was justified by JFD 40. PTS 6.5.2 uses the same words as Unit 1 LC 2.C.(5) and Unit 2 LC 2.C.(5), and thus is inconsistent with ITS 5.5.2. See Comment Number 1.0-1. Comment: See Comment Numbers 1.0-1 and 6.0-1.
ANO-2 Response:
6.0-16 DOC A.1 DOG A.17 JFD41 JFD 42 1CTS 6.8.5 2CTS 6.8.4.a ITS 5.5.4 PTS 6.5.4 1CTS 6.8.5 and 2 CTS 6.8.4.a use the exact same words. In converting 1CTS 6.8.5 to ITS 5.5.4 a number of changes were made. The 1CTS markup shows these changes as inserts 127aA through 127aD, as well as other changes. These changes are justified by DOCs A.1 and A.17 and JFDs 41 and 42. In converting 2CTS 6.8.4.a to PTS 6.5.4 only one of the 1 CTS to ITS changes was incorporated. The adding of "The provisions of TS 4.0.2... frequency." The justification for this change is inadequate-clarity is not an acceptable justification. In addition, in other ANO-2 specifications, 10 CFR 20 has been changed to reflect the new numbering system for 10 CFR 20; it has not been done here.
See Comment Numbers 1.0-1 and 6.0-1. Comment: Provide a discussion and justification for this Administrative change and the inconsistencies between the ITS and PTS. See Comment Numbers 1.0-1 and 6.0-1.
ANO-2 Response:
6.0-17 1CTS 4.0.5 2CTS 6.5.8 ITS 5.5.8 PTS 6.5.8 In converting 1CTS 4.0.5 to ITS 5.5.8, an editorial change was made to the ASME terminology header. The title "ASME Boiler and Pressure Vessel Code and applicable Addenda Terminology..." was changed to "ASME Code Terminology..." 2CTS 6.5.8/PTS 5.5.8 does not make this change, which results in an inconsistency. Comment: See Comment Number 6.0-1.
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David Jaffe -Arkansasrai.wpd Page 14 ANO-2 Response:
6.0-18 2CTS 4.5.5.0 Note PTS 6.5.9 2CTS 4.5.5.0 has a Note associated with it which states: "The requirements for inservice inspection...replacement outage (2R14)." In relocating 2CTS 4.5.5.0 to PTS 6.5.9 the Note has been deleted. No justification is provided for this deletion. Comment: Provide a discussion and justification for deleting this Note.
ANO-2 Response:
6.0-19 DOC A.1 Unit 1 LC 2.C.(7)
Unit 2 LC 2.C.(3) (p)
ITS 5.5.10 PTS 6.5.10 Unit I LC 2.C.(7) and Unit 2 LC 2.C.(3)(p) use virtually the same words. In converting Unit 1 LC 2.C.(7) to ITS 5.5.10, the following changes were made: 1) The program title deletes "monitoring," 2) The words "A secondary water chemistry monitoring program shall be implemented to minimize..." were changed to "This program provides controls for monitoring secondary water chemistry to inhibit...", and 3) the word "Parameters" in items 1 and 2 are changed to "variables". These changes were justified by DOC A.1.
PTS 6.5.10 uses the exact same words as Unit 2 LC 2.C.(3)(p) with no changes and this is inconsistent with ITS 5.5.10. See Comment Number 1.0-1. Comment: See Comment Numbers 1.0-1 and 6.0-1.
ANO-2 Response:
6.0-20 DOC A.3 DOC A.8 DOC M.5 DOC M.10 DOC M.11 DOC LA.3 JFD 13 1CTS 3.15.1, 4.10.2.b, 4.10.2.c, 4.10.2.d, 4.10.2.e, 4.10.2.f, 4.17.1, 4.17.2 and 4.17.3 2CTS 4.7.6.1.2.b, 4.7.6.1.2.c, 4.7.6.1.2.d, 4.7.6.1.2.e, 4.7.6.1.2.f, and 4.9.11.2 ITS 5.5.11 14
David Jaffe - Arkansasrai.wpd PTS 6.5.11 STS 5.5.11 In converting the above referenced 1CTS 3.15.1, 4.10.2, and 4.17specifications to ITS 5.5.11, a number of changes were made which include deviations from STS 5.5.11.
These changes were justified by DOCs A.3, A.8, M.5, M.10, M.11, and LA.3 and JFD 13.
In converting the above referenced 2CTS 4.7.6.1.2 and 4.9.11.2 specifications to PTS 6.5.11, no changes were made to the format and wording of the specifications, except for the adding of the words "The provisions of...surveillance frequency." The only justifications provided are consistency and clarity. PTS 6.5.11 is not consistent with ITS 5.5.11 from a format standpoint and clarity is not an adequate justification for a change.
See Comment Number 1.0-1. Comment: See Comment Numbers 1.0-1 and 6.0-1.
ANO-2 Response:
6.0-21 DOC A.3 DOC LA.5 JFD 34 1CTS 3.24, 3.25, 3.25.2, 4.28, 4.29.1 and 4.29.2 ITS 5.5.12 In converting 1CTS 3.24, 3.25.1, 3.25.2, 4.28, 4.29.1 and 4.29.2 to ITS 5.5.12 a number of changes were made. These changes were justified by DOCs A.3 and LA.5 and JFD
- 34. PTS 6.5 does not contain an equivalent program to ITS 5.5.12. Nothing in the Amendment package addresses this aspect. It is unclear whether explosive gas and storage tank systems are common or shared by both units. If they are, then a program similar to ITS 5.5.12 should be provided. If they are not, then an explanation as to why it should not be included should be provided since similar programs for possible independent systems were proposed for ANO-2 (i.e., diesel fuel oil). Comment: Provide a discussion and justification for the concerns on the Explosive Gas and Storage Tank Monitoring System.
ANO-2 Response:
6.0-22 DOC A.3 DOC M.9 DOC L.6 DOC LA.3 JFD 14 JFD 16 JFD 38 1CTS 4.6.1.4.e 2CTS 4.8.1.1.2.b ITS 5.5.13 15 Page 15
David Jaffe - Arkansasrai.wpd PTS 6.5.13 STS 5.5.13 In converting 1 CTS 4.6.1.4.e and STS 5.5.13 to ITS 5.5.13 a number of changes were made to 1 CTS and the STS. These changes were justified by DOCs A.3, M.9, L.6 and LA.3 and JFDs 14, 16, and 38. The wording/requirements in 2CTS 4.8.1.1.2.b is similar to 1 CTS 4.6.1.4.e except for the frequency (92 days versus 31 days respectively). The concern expressed in Comment Number 3/4.8-1 about diesel fuel oil system commonalities also applies here. If there is a commonality, then the programs should be consistent, with regard to new fuel testing and fuel oil specifications. If they are not common, why shouldn't the test program be the same/consistent? In either case, PTS 6.5.13 should have a statement on 2CTS 4.0.2/4.0.3 applicability as was done on the other programs in this section. See Comment Number 1.0-1. Comment: Revise PTS 6.5.13 in accordance with the above discussion and provide the appropriate discussions and justifications. See Comment Numbers 3/4.8-1, 1.0-1 and 6.0-1.
ANO -2 Response:
6.0-23 DOC LA.6 1CTS 6.12.2.1 2CTS 6.9.1 In converting 1CTS to the ITS, the details contained in ICTS 6.12.2.1 were relocated to the Technical Requirements Manual (TRM). This relocation was justified by DOC LA.6.
In converting 2CTS to the PTS, the corresponding 2CTS requirements are deleted and the associated SAR statement on conformance to Regulatory Guide (RG) 1.16 being specified in the TS is modified to reflect this change. No mention is made on where the details contained in 2CTS 6.9.1 went or how ANO-2 conforms to the guidelines of Regulatory Guide (RG) 1.16, as stated in the current SAR. See Comment Number 1.0-1. Comment: Provide a discussion and justification as to where the details contained in 2CTS 6.9.1 are to be located. See Comment Number 1.0-1.
ANO-2 Response:
6.0-24 DOC A.13 DOC L.3a JFD 26 1CTS 6.12.2.2 2CTS 6.9.1.4 and 6.9.1.5.a ITS 5.6.1 PTS 6.6.1 STS 5.6.1 16 Page 16
David Jaffe - Arkansasrai.wpd Page 17 In converting 1CTS 6.12.2.2 and STS 5.6.1 to ITS 5.6.1, a number of changes were made to lCTS 6.12.2.2 and STS 5.6.1. These changes were justified by DOCs A.13 and L.3a and JFD 26. In converting 2CTS 6.9.1.4 and 6.9.1.5.a to PTS 6.6.1 the same changes made to 1CTS 6.12.2.2 and STS 5.6.1 were also made here. These Administrative and Less Restrictive (L) changes were not adequately justified. See Comment Number 1.0-1. Comment: Provide a justification and discussion for these Administrative and Less Restrictive (L) changes. See Comment Number 1.0-1.
ANO-2 Response:
6.0-25 DOC A.14 JFD 26 1CTS 6.12.2.6 2CTS 6.9.3 ITS 5.6.3 2CTS 6.9.3 ITS 5.6.3 PTS 6.6.3 STS 5.6.3 In converting lCTS 6.12.2.6 and STS 5.6.3 to ITS 5.6.3 a number of changes were made to 1CTS 6.12.2.6 and STS 5.6.3. These changes were justified by DOC A.14 and JFD 26. In converting 2CTS 6.9.3 to PTS 6.6.3, some of these changes were made and others were not. No justification is provided for these changes and inconsistencies between the ITS and PTS. See Comment Number 1.0-1. Comment: Provide a discussion and justification for these Administrative changes and inconsistencies. See Comment Numbers 1.0-1 and 6.0-1.
ANO-2 Response:
6.0-26 lCTS 6.12.3 2CTS 6.9.5 ITS 5.6.5 PTS 6.6.5 STS 5.6.5 In converting 1CTS 6.12.3 to ITS 5.6.5 some editorial word changes were made to make the specification consistent with STS 5.6.5. In converting 2CTS 6.9.5 to PTS 6.6.5 some of these editorial changes were made and others were not. No justification was provided for the inconsistency between ITS/STS 5.6.5 and PTS 6.6.5. Comment: See Comment Number 6.0-1.
ANO Response:
17 David,Jaffe - Arkansasrai~wpd Page 17
David Jaffe - Arkansasrai.wpd Page 18 6.0-27 2CTS 4.4.5.5.c PTS 6.6.7.c 2CTS 4.4.5.5.c states that the results of category C-3 steam generator tube inspections "shall be reported in a Special Report pursuant to specification 6.9.2...". The wording in the markup of PTS 6.6.7.c is different than the wording in the typed version of PTS 6.6.7.c with regard to this special report. See Comment Number 6.0-29. Comment:
Correct this inconsistency. See Comment Number 6.0-29.
ANO-2 Response:
6.0-28 2CTS 6.9.1.5.e PTS 6.6.8 2CTS 6.9.1.5.e is relocated to PTS 6.6.8. The justification for the relocation states that the specification will be retained with no technical changes proposed. This is incorrect.
The markup of 2CTS 6.9.1.5.e shows that information required by 2CTS 6.9.1.5.e.(3) deletes the starting time criteria, and 2CTS 6.9.1.5.e.(4) and 6.9.1.5.e.(5) have been deleted. No justification has been provided for these Less Restrictive changes.
Comment: Provide a discussion and justification for these Less Restrictive changes.
ANO-2 Response:
6.0-29 DOC A.5 1CTS 6.12.5 2CTS Table 3.3-6 Actions 18 and 19 2CTS Table 3.3-10 Actions 3:b and 4:b 2CTS 4.4.5.5.c 2CTS 3.5.2 Action b 2CTS 3.5.3 Action b 2CTS 3.7.12 Action a 2CTS 6.9.2, 6.9.2.a, 6.9.2.i, 6.9.2.j, 6.9.2.k, 6.9.2.k, 6.9.2.n and 6.9.2.o PTS Table 3.3-6 Actions 18 and 19 PTS Table 3.3-10 Actions 3:b and 4:b PTS 3.5.2 Action b PTS 3.5.3 Action b PTS 3.7.12 Action a PTS 6.6.7.c 2CTS Table 3.3-6, Table 3.3-10, 4.4.5.5.c, 3.5.2, 3.5.3 and 3.7.12 specify that special reports shall be submitted to the Commission pursuant to 2CTS 6.9.2. 2CTS 6.9.2 18
David -Jaffe - Arkansasrai.wpd states that these special reports shall be submitted to the Administrator of the Regional Office.
In converting the above 2CTS specifications to the corresponding PTS specifications the reference to 2CTS6.9.2 was changed to "to the NRC" except for 2CTS 4.4.5.5.c/PTS 6.6.7.c (See Comment Number 6.0-27), and 2CTS 6.9.2 was deleted. The proposed change does not specify to whom the special reports are to be sent, other than the NRC. This change has not been justified. A similar change was made in converting 1CTS 6.12.5 (The ANO-1 corresponding specification) to the ITS and was justified by DOC A.5. See Comment Number 1.0-1. Comment: Provide a discussion and justification for this Administrative change. See Comment Number 1.0-1.
ANO-2 Response:
6.0-30 DOC L.3b JFD 42 1CTS 6.12.2.4 2CTS 6.9.1.5.c ITS 5.6.4 STS 5.6.4 2CTS 6.9.1.5.c requires that all challenges to the pressurizer safety valves be documented and included in the annual report. ICTS 6.12.2.4 and STS 5.6.4 had a similar requirement but it was deleted by DOC L.3b, JFD 42 and TSTF 258. The deletion of this requirement from the PTS was justified by reference to TSTF-258. This part of the change is acceptable. However, the justification provided for the deletion of this requirement also states that this specification encompassed a commitment to report all challenges to the Low Temperature Overpressure Protection (LTOP) safety valves. No information or justification was provided with regard to the deletion of the reporting requirement for the LTOP safety valves; The justification only discussed the pressurizer safety valves. Comment: Provide additional justification and discussion on the deletion of the reporting requirement for LTOP safety valve challenges.
ANO-2 Response:
6.0-31 DOC A.1 DOC L.2 JFD 42 ICTS 6.11 2CTS 6.13 ITS 5.7 PTS 6.7 STS 5.7 In converting 1 CTS 6.11 and STS 5.7 to ITS 5.7, a number of changes were made to 19 Page 19
David Jaffe - Arkansasrai.wpd Page 20 1CTS 6.11 and STS 5.7. These changes were justified by DOCs A. 1 and L.2 and JFD
- 42. 1CTS 6.11 and 2CTS 6.13 both use the exact same wording as do ITS 5.7 and PTS 6.7. The same conversion changes made to ICTS 6.11 and STS 5.7 were made to 2CTS 6.13 and PTS 6.7. The justification provided for these changes in the amendment package was consistency and editorial. This justification is insufficient. See Comment Number 1.0-1. Comment: Provide a discussion and justification for the Administrative and Less Restrictive changes as well as the deviations from the STS. See Comment Number 1.0-1.
ANO-2 Response:
20
';David Jaffe - Arkansasrai.wpd Page 20
Page 21 TABLE I Cross Reference of Inconsistent Specifications Between Unit 1 and Unit 2 Unit 1 lCTS 6.1.1 1CTS 6.1.2 I CTS 6.2.1 1CTS 6.2. 1.b lCTS 6.2.1.c lCTS Table 6.2.1 Note #
ICTS 6.3.1 1CTS 6.14 LC 2.C.(5) 1CTS 6.8.5 1CTS 4.0.5 LC2.C.(7)
ICTS 3.15.1, 4.10.2.b,c,d,e,&f, 4.17,1,2, &3 1CTS 4.6.1.4.e 1CTS 6.12.2.6 1CTS 6.12.3 Unit 1 ITS 5.1.1 5.1.2 5.2.1 5.2.1.b 5.2.1.c 5.2.2.c 5.3.1 5.4.c 5.5 5.5.1 5.5.2 5.5.4 5.5.8 5.5.10 5.5.11 5.5.13 5.6.3 5.6.5 Unit 2 2CTS 6.1.1 2CTS 6.1.2 2CTS 6.2.1 2CTS 6.2.1.b 2CTS 6.2.1.c 2CTS Table 6.2.1 Note #
2CTS 6.3.1 2CTS 6.8.4 2CTS 6.14 LC 2.C.(5) 2CTS 6.8.4.a 2CTS 6.5.8 LC 2.C.(3)(p) 2CTS 4.7.6.1.2, b,c, d, e, f, and 4.9.11.2 6.2.1.,
6.2.1.4 6.2.2.4 2CTS 4.8.1.1.2.b 2CTS 6.9.3 2CTS 6.9.5 21 Unit 2 PTS 6.1.1 6.1.2 6.2.1 b
c 6.3.1 6.4.d 6.5 6.5.1 6.5.2 6.5.4 6.5.8 6.5.10 6.5.11 6.5.13 6.6.3 6.6.5 SDavid Jaffe - Arkansasrai.wpd