2CAN020405, Supplement to Amendment Request Related to the Revision of Section 6.0, Administrative Controls

Supplement to Amendment Request Related to the Revision of Section 6.0, Administrative Controls

ML040620499
Person / Time
Site:	Arkansas Nuclear  (NPF-006)
Issue date:	02/27/2004
From:	Eubanks C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN020405
Download: ML040620499 (24)

Text

Entergy Operations, Inc.

Entergy1448 SR. 333 Russeilville, AR 72802 Tel 501858 5000 2CAN020405 February 27, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplement to Amendment Request Related to the Revision of Section 6.0, Administrative Controls Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1.

Entergy letter dated June 30, 2003, License Amendment Request Revision of Section 6.0, Administrative Controls (2CAN060303)

2.

Entergy letter dated November 20, 2003, Supplement to Amendment Request Related to the Revision of Section 6.0, Administrative Controls (2CAN1 10301)

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) to: 1) reorganize Section 6.0, Administrative Controls; 2) modify the actions and surveillance requirements (SRs) of various other TSs to support the reorganization; 3) modify several actions and SRs that are related to systems that are shared by ANO-2 and ANO, Unit 1 (ANO-1); and 4) change various TS bases as needed to support the above changes. By letter (Reference 2),

Entergy responded to an NRC request for additional information related to the proposed change.

Entergy and members of your staff held a call to discuss administrative corrections that were needed to several of the TS pages, which were included as part of the original and supplemental submittals. A summary of the changes is included in Attachment 1. The modified clean pages are contained in Attachment 2. Page I of the Index which was included in the original submittal (Reference 1), is being withdrawn. No change is needed to this page.

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.

poCM

2CAN020405 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 27, 2004.

Sincere!

Clifford Eubanks General Manager, Plant Operations CE/dm Attachments:

1. Summary of Changes

2. Revised Technical Specification Clean Pages 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. Thomas W. Alexion MS 0-7D1 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

Attachment I To 2CAN020405 Summary of Changes to 2CAN020405 Page 1 of 1 The following changes were made based on discussions with your staff:

Operating License page 6 o the header was added o In item 3.10 the "u" in "upper" will be changed from lower case to a upper case "Upper". This is a new editorial change.

o The line at the bottom of the page after item 3.20 and before the statement

"(Numbers in parentheses...)" was change from a dashed line to a solid line.

Operating License page 7 o Item (i), the amendment number and approval date, amendment 102, dated 12-14-89, was added in the right margin.

o Item 2.C(3)(k) - deleted "No." in the phrase "Amendment No. 31" Index page I - this page is being deleted from the submittal. The proposed change was not needed.

Index page III - in the page header "SAFETY SYSTEMS" was changed to "SAFETY SYSTEM" Index page Xl - Technical Specification (TS) Section 3/4.1.2 was added to the page and identified as deleted.

Index page XIII - TS Section 3/4.7.9 was added to the page and Section 3/4.7.11 was deleted.

Index page XVI - A revision bar was added next to "6.0 ADMINISTRATIVE CONTROLS" TS page 3/4 1-4 -A revision bar was added next to "LIMITING CONDITION FOR OPERATION" TS page 3/4 7 Action "e" - "with" was added after "or" so the action in part reads

"...ACTION d or with two control room..."

> TS page 3/4 7-17a - Amendment numbers 206 and 219 were added to the bottom of the page and shown as deleted.

> TS page 3/4 7-23b - in the last sentence of Oh" "replacement" was changed to "replacements".

> TS page 3/4 8 the "s" was deleted from REQUIREMENTS in the header "SURVEILLANCE REQUIREMENTS" TS pages 3/4 9-1 and 10 A reference to a correction letter was added in the footer.

TS page 6 TS 6.5.3.a - "Training personnel" was changed to "Training of personnel."

TS page 6 TS 6.5.8, the header on the table listing the testing frequencies was changed from double spacing to single spacing.

TS page 6 In the second sentence of the introductory paragraph of TS 6.5.9.2 "specification" was changed to "Specification" (upper case "S") before the referenced TS 6.5.9.3.

TS page 6 The entry sentence before the category and inspection results table in part currently states "...into one to the following..." This will be changed to "...into one of the following..." This is a new editorial change correcting grammar only.

TS page 6 the line spacing in the Action Required column for Result C-2 was adjusted.

TS page 6-14 o TS 6.5.10.d - the us" in "Procedures" was deleted.

O TS 6.5.10.f - a comma was added after the word "data" "...data, and the..."

To 2CAN020405 Revised Technical Specification Clean Pages Implementation Dates for Proposed Modifications (Continued)

Applicable Section of NUREG-0223 Date 3.9 3.10 3.11 3.12 Protection of Redundant Cables in the Lower South Electrical Penetration Room (211 1-T)

Protection of Safe Shutdown Cables in the Upper South Piping Penetration Room (2084-DD)

Protection of Redundant Reactor Protection System Cables (2136-1)

Fire Dampers September 30, 1978 September 30, 1978 September30, 1978 I

3.13 3.14 3.15 3.16 Portable Extinguisher for the Control Room (2199-J)

November 15,1978 Smoke Detectors Manual Hose Stations (2055-JJ, 2084-DD, Containment, Elev. 317' of Auxiliary Building)

Portable Smoke Exhaust Equipment December 1, 1978 3.17 3.18 Emergency Lighting December 1, 1978 Reactor Coolant Pump Oil Collection System 3.19 3.20 Control of Fire Doors Administrative Control Changes March 31, 1979 December 1, 1978 (Numbers in parentheses refer to fire zone designations in the AP&L fire hazards analysis.)

• Prior to startup following the first regularly scheduled refueling outage.

• • Technical Specifications covering these items should be proposed not later than 90 days prior to implementation.

2.C.(3)(0 Deleted per Amendment 24, 6/19/81.

2.C.(3)(g) Deleted per Amendment 93, 4/25189.

2.C.(3)(h) Deleted per Amendment 29, (314/82) and its correction letter, (3/15/82).

(i) Containment Radiation Monitor Am. 102.

AP&L shall, prior to July 31, 1980 submit for Commission review and 12-14-89 approval documentation which establishes the adequacy of the qualifications of the containment radiation monitors located inside the containment and shall complete the installation and testing of these instruments to demonstrate that they meet the operability requirements of Technical Specification No. 3.3.3.6.

2.C.(3)0)

Deleted per Amendment 7, 12/1/78.

2.C.(3)(k) Deleted per Amendment 12, 6/12179 and Amendment 31, 5/12/82.

2.C.(3)(1)

Deleted perAmendment 24, 6/19/81.

2.C.(3)(m) Deleted per Amendment 12, 6/12/79.

2.C.(3)(n) Deleted per Amendment 7, 12/1178.

2.C.(3)(o) Deleted perAmendment7, 12/1/78.

2.C.(3)(p) Deleted per Amendment

INDEX SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS SECTION PAGE 2.1 SAFETY LIMITS Reactor Core.............................................................

2-1 Reactor Coolant System Pressure.............................................................

2-2 2.2 LIMITING SAFETY SYSTEM SETTINGS Reactor Trip Setpoints.............................................................

2-3 BASES SECTION PAGE 2.1 SAFETY LIMITS Reactor Core.............................................................

B 2-1 Reactor Coolant System Pressure.............................................................

B 2-2 2.2 LIMITING SAFETY SYSTEM SETTINGS Reactor Trip Setpoints.............................................................

B 2-2 ARKANSAS - UNIT 2 III Amendment No. 24,60,7,

INDEX BASES SECTION PAGE 3/4.0 APPLICABILITY...........................................................

B 3/4 0-1 3/4.1 REACTIVITY CONTROL SYSTEMS 3/4.1.1 BORATION CONTROL............................................................................

B 3/4 1-1 3/4.1.2 Deleted 3/4.1.3 MOVABLE CONTROL ASSEMBLIES......................................................

B 3/4 1-3 3/4.2 POWER DISTRIBUTION LIMITS 3/4.2.1 LINEAR HEAT RATE...............................................................................

B 3/4 2-1 3/4.2.2 RADIAL PEAKING FACTORS.B 3/4 2-2 3/4.2.3 AZIMUTHAL POWER TILT - Tq.B 3/4 2-2 3/4.2.4 DNBR MARGIN........................................................................................

B 3/4 2-3 3/4.2.5 RCS FLOW RATE....................................................................................

B 3/4 2-4 3/4.2.6 REACTOR COOLANT COLD LEG TEMPERATURE.B 3/4 2-4 3/4.2.7 AXIAL SHAPE INDEX..............................................................................

B 3/4 2-4 3/4.2.8 PRESSURIZER PRESSURE...................................................................

B 3/4 2-4 3/4.3 INSTRUMENTATION 3/4.3.1 PROTECTIVE INSTRUMENTATION B 3/4 3-1 3/4.3.2 ENGINEERED SAFETY FEATURES (ESF) INSTRUMENTATION..........

B 3/4 3-1 3/4.3.3 MONITORING INSTRUMENTATION B 3/4 3-2 ARKANSAS - UNIT 2 Xi Amendment No. 24,33,60,494,

INDEX BASES SECTION PAGE 3/4.7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE.B 3/4 7-1 3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION B 3/4 7-4 3/4.7.3 SERVICE WATER SYSTEM.B 3/4 7-4 3/4.7.4 EMERGENCY COOLING POND..............................................................

B 3/4 7-4 3/4.7.5 FLOOD PROTECTION.B 3/4 7-4 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM...........................................................

B 3/4 7-5 3/4.7.8 SHOCK SUPPRESSORS (SNUBBERS)..................................................

B 3/4 7-6 3/4.7.9 SEALED SOURCE CONTAMINATION....................................................

B 3/4 7-7 3/4.7.12 SPENT FUEL POOL STRUCTURAL INTEGRITY....................................

B 3/4 7-7 3/4.8 ELECTRICAL POWER SYSTEMS..............................................................

B 3/4 8-1 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION.................................................

B 3/4 9-1 3/4.9.2 INSTRUMENTATION...........................................................

B 3/4 9-1 3/4.9.3 DECAY TIME...........................................................

B 3/4 9-1 3/4.9.4 CONTAINMENT PENETRATIONS..........................................................

B 3/4 9-1 ARKANSAS - UNIT 2 Xlll Amendment No. 60,62,206,

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6-1 6.2 ORGANIZATION 6.2.1 Onsite and Offsite Organizations.6-1 6.2.2 Unit Staff.6-2 6.3 UNIT STAFF QUALIFICATIONS 6-3 6.4 PROCEDURES 6-3 6.5 PROGAMS AND MANUALS 6.5.1 Offsite Dose Calculation Manual (ODCM).

6-4 6.5.2 Primary Coolant Sources Outside Containment.6-5 6.5.3 Iodine Monitoring.6-5 6.5.4 Radioactive Effluent Controls Program.6-5 6.5.5 Component Cyclic or Transient Limit Program.6-6 6.5.7 Reactor Coolant Pump Flywheel Inspection Program.6-6 6.5.8 Inservice Testing Program.6-7 6.5.9 Steam Generator (SG) Tube Surveillance Program.6-8 6.5.10 Secondary Water Chemistry.6-14 6.5.11 Ventilation Filter Testing Program (VFTP).6-15 6.5.13 Diesel Fuel Oil Testing Program.6-16 6.5.14 Technical Specification (TS) Bases Control Program.6-17 6.5.16 Containment Leakage Rate Testing Program.6-18 ARKANSAS - UNIT 2 XVI Amendment No. 60,460,

REACTIVITY CONTROL SYSTEMS BORON DILUTION LIMITING CONDITION FOR OPERATION 3.1.1.3 The flow rate of reactor coolant through the reactor coolant system shall be 2 2000 gpm whenever a reduction in Reactor Coolant System boron concentration is being made.

APPLICABILITY:

ALL MODES.

ACTION:

With the flow rate of reactor coolant through the reactor coolant system < 2000 gpm, immediately suspend all operations involving a reduction in boron concentration of the Reactor Coolant System.

SURVEILLANCE REQUIREMENTS 4.1.1.3 The flow rate of reactor coolant through the reactor coolant system shall be determined to be Ž 2000 gpm within one hour prior to the start of and at least once per hour during a reduction in the Reactor Coolant System boron concentration by either:

a.

Verifying at least one reactor coolant pump is in operation, or

b.

Verifying that at least one low pressure safety injection pump or containment spray pump is in operation as a shutdown cooling pump and supplying 2 2000 gpm through the reactor coolant system.

ARKANSAS - UNIT 2 3/4 1-4 Amendment No. 42A,

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent control room emergency ventilation and air conditioning systems shall be OPERABLE. (Note 1)

APPLICABILITY:

MODES 1, 2, 3, 4, or during handling of irradiated fuel.

ACTION:

MODES 1. 2. 3. and 4

a.

With one control room emergency air conditioning system inoperable, restore the inoperable system to OPERABLE status within 30 days 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 />.

b.

With one control room emergency ventilation system inoperable, restore the inoperable system to OPERABLE status within 7 days 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 />.

c.

With one control room emergency air conditioning system and one control room emergency ventilation system inoperable, restore the inoperable control room emergency ventilation system to OPERABLE status within 7 days and restore the inoperable control room emergency air conditioning system to OPERABLE status within 30 days 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 />.

d.

With two control room emergency ventilation systems inoperable due to an inoperable control room boundary, restore the control room boundary to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 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 />.

e.

With two control room emergency ventilation systems inoperable for reasons other than ACTION d or with two control room emergency air conditioning systems inoperable, enter Specification 3.0.3.

During Handling of Irradiated Fuel

f.

With one control room emergency air conditioning system inoperable, restore the inoperable system to OPERABLE status within 30 days or immediately place the OPERABLE system in operation; otherwise, suspend all activities involving the handling of irradiated fuel. The provisions of Specification 3.0.4 are not applicable.

g.

With one control room emergency ventilation system inoperable, restore the inoperable system to OPERABLE status within 7 days or immediately place the control room in the emergency recirc mode of operation; otherwise, suspend all activities involving the handling of irradiated fuel. The provisions of Specification 3.0.4 are not applicable.

Note 1: The control room boundary may be open intermittently under administrative controls.

ARKANSAS - UNIT 2 3/4 7-1 7 Amendment No. 206,24-9,

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION

h.

With one control room emergency air conditioning system and one control room emergency ventilation system inoperable:

1. restore the inoperable control room emergency ventilation system to OPERABLE status within 7 days or immediately place the control room in the emergency recirc mode of operation, and

2.

restore the inoperable control room emergency air conditioning system to OPERABLE status within 30 days or immediately place the OPERABLE system in operation;

3. otherwise, suspend all activities involving the handling of irradiated fuel.

4. The provisions of Specification 3.0.4 are not applicable.

i.

With both control room emergency air conditioning systems or both control room emergency ventilation systems inoperable, immediately suspend all activities involving the handling of irradiated fuel.

ARKANSAS - UNIT 2 3/4 7-17a Amendment No. 206,2, I

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

If any snubber selected for functional testing either fails to activate or fails to move, i.e., frozen-in-place, the cause will be evaluated and, if caused by manufacturer or design deficiency, all snubbers of the same type subject to the same defect shall be evaluated in a manner to ensure their OPERABILITY. This requirement shall be independent of the requirements stated in Specification 4.7.8.d for snubbers not meeting the functional test acceptance criteria.

g.

Preservice Testing of Repaired, Replacement and New Snubbers Preservice operability testing shall be performed on repaired, replacement or new snubbers prior to installation. Testing may be at the manufacturer's facility. The testing shall verify the functional test acceptance criteria in 4.7.8.e.

In addition, a preservice inspection shall be performed on each repaired, replacement or new snubber and shall verify that:

1) There are no visible signs of damage or impaired operability as a result of storage, handling or installation;

2) The snubber load rating, location, orientation, position setting and configuration (attachment, extensions, etc.), are in accordance with design;

3) Adequate swing clearance is provided to allow snubber movement;

4)

If applicable, fluid is at the recommended level and fluid is not leaking from the snubber system;

5) Structural connections such as pins, bearings, studs, fasteners and other connecting hardware such as lock nuts, tabs, wire, and cotter pins are installed correctly.

h.

Snubber Seal Replacement Program The seal service life of hydraulic snubbers shall be monitored to ensure that the service life is not exceeded between surveillance inspections. The expected service life for the various seals, seal materials, and applications shall be determined and established based on engineering information and the seals shall be replaced so that the expected service life will not be exceeded during a period when the snubber is required to be OPERABLE. The seal replacements shall be documented.

ARKANSAS - UNIT 2 3/4 7-23b Amendment No. 62-,

ELECTRICAL POWER SYSTEMS SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

One circuit between the offsite transmission network and the onsite Class I E distribution system, and

b.

One diesel generator with:

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

2. A fuel storage system, and

3. A fuel transfer pump.

APPLICABILITY:

MODES 5 and 6.

ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENT 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for Requirement 4.8.1.1.2a.5.

ARKANSAS - UNIT 2 3/4 8-5 Amendment No. 44,

3/4.9 REFUELING OPERATIONS BORON CONCENTRATION LIMITING CONDITION FOR OPERATION 3.9.1 With the reactor vessel head unbolted or removed, the boron concentration of the reactor coolant and the refueling canal shall be maintained uniform and sufficient to ensure that the more restrictive of following reactivity conditions is met:

a.

Either a Keff of 0.95 or less, which includes a 1 % Ak/k conservative allowance for uncertainties, or

b.

A boron concentration of 2 2500 ppm, which includes a 50 ppm conservative allowance for uncertainties.

APPLICABILITY:

MODE 6*.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes and initiate and continue boration at Ž 40 gpm of 2 2500 ppm boric acid solution until Keff is reduced to

• 0.95 or the boron concentration is restored to 2 2500 ppm, whichever is the more restrictive. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.1.1 The more restrictive of the above two reactivity conditions shall be determined prior to:

a.

Removing or unbolting the reactor vessel head, and

b.

Withdrawal of any CEA in excess of 3 feet from its fully inserted position within the reactor pressure vessel.

4.9.1.2 The boron concentration of the reactor coolant and the refueling canal shall be determined by chemical analysis at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

• The reactor shall be maintained in MODE 6 when the reactor vessel head is unbolted or removed.

ARKANSAS - UNIT 2 3/4 9-1 Amendment No. 82,469, Correction Letter dnted-10/24/95

SPECIAL TEST EXCEPTIONS GROUP HEIGHT. INSERTION AND POWER DISTRIBUTION LIMITS LIMITING CONDITION FOR OPERATION 3.10.2 The group height, insertion and power distribution limits of Specifications 3.1.1.4, 3.1.3.1, 3.1.3.5, 3.1.3.6, 3.2.2, 3.2.3,3.2.7 and the Minimum Channels OPERABLE requirement of Functional Unit 14 of Table 3.3-1 may be suspended during the performance of PHYSICS TESTS provided:

a.

The THERMAL POWER is restricted to the test power plateau which shall not exceed 85% of RATED THERMAL POWER, and

b.

The linear heat rate limit shall be maintained by either:

1. Maintaining COLSS calculated core power less than or equal to COLSS calculated core power operating limit based on linear heat rate (when COLSS is in service); or

2.

Operating within the region of acceptable operation as specified in the CORE OPERATING LIMITS REPORT using any operable CPC channel (when COLSS is out of service.)

APPLICABILITY:

During startup and PHYSICS TESTS.

ACTION:

With any of the above limits being exceeded while any of the above requirements are suspended, either:

a.

Reduce THERMAL POWER sufficiently to satisfy the requirements of the above Specification, or

b.

Be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.10.2.1 The THERMAL POWER shall be determined at least once per hour during PHYSICS TESTS in which any of the above requirements are suspended and shall be verified to be within the test power plateau.

4.10.2.2 The linear heat rate shall be determined to be within its limits during PHYSICS TESTS above 5% of RATED THERMAL POWER in which any of the above requirements are suspended.

ARKANSAS - UNIT 2 3/4 10-2 Amendment No. 37,405,457,469, Correction Letter dated 10!24195

-1 ADMINISTRATIVE CONTROLS 6.5 PROGRAMS AND MANUALS 6.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The program shall include the following:

a.

Preventive maintenance and periodic visual inspection requirements; and

b.

Integrated leak test requirements for each system at least once per 18 months.

The provisions of Surveillance Requirements 4.0.2 are applicable.

6.5.3 Iodine Monitorinq This program provides controls that ensure the capability to accurately determine the airborne iodine concentration under accident conditions. The program shall include the following:

a.

Training of personnel;

b.

Procedures for monitoring; and

c.

Provisions for maintenance of sampling and analysis equipment.

6.5.4 Radioactive Effluent Controls Program This program conforms with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a.

Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;

b.

Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS, conforming to 10 CFR 20, Appendix B, Table II, Column 2;

c.

Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM;

d.

Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS, conforming to 10 CFR 50, Appendix I; ARKANSAS - UNIT 2 6-5 Amendment No.

ADMINISTRATIVE CONTROLS 6.5.8 Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components. The program shall include the following:

a. Testing frequencies specified in Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as follows:

ASME Code terminology for inservice testing activities Required frequencies for performing inservice testing activities Weekly Monthly Every 6 weeks Quarterly or every 3 months Semiannually or every 6 months Every 9 months Yearly or annually Biennially or every 2 years At least once per 7 days At least once per 31 days At least once per 42 days At least once per 92 days At least once per 184 days At least once per 276 days At least once per 366 days At least once per 731 days

b. The provisions of Specification 4.0.2 are applicable to the above required frequencies for performing inservice testing activities.

c.

The provisions of Specification 4.0.3 are applicable to inservice testing activities, and

d. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any Technical Specification.

ARKANSAS - UNIT 2 6-7 Amendment No.

ADMINISTRATIVE CONTROLS 6.5.9 Steam Generator (SG) Tube Surveillance Program 6.5.9.1 Steam Generator Sample Selection and Inspection Each steam generator shall be determined OPERABLE during shutdown by selecting and inspecting at least the minimum number of steam generators specified in Table 6.5.9-1.

6.5.9.2 Steam Generator Tube Sample Selection and Inspection The steam generator tube minimum sample size, inspection result classification, and the corresponding action required shall be as specified in Table 6.5.9-2. The inservice inspection of steam generator tubes shall be performed at the frequencies specified in Specification 6.5.9.3 and the inspected tubes shall be verified acceptable per the acceptance criteria of Specification 6.5.9.4. The tubes selected for each inservice inspection shall include at least 3% of the total number of tubes in all steam generators; the tubes selected for these inspections shall be selected on a random basis except:

a.

Where experience in similar plants with similar water chemistry indicates critical areas to be inspected, then at least 50% of the tubes inspected shall be from these critical areas.

b.

The first sample of tubes selected for each inservice inspection (subsequent to the pre-service inspection) of each steam generator shall include:

1.

All non-plugged tubes that previously had detectable wall penetrations

(>20%).

2.

Tubes in those areas where experience has indicated potential problems.

3.

A tube inspection (pursuant to Specification 6.5.9.4.a.9) shall be performed on each selected tube. If any selected tube does not permit the passage of the eddy current probe for a tube inspection, this shall be recorded and an adjacent tube shall be selected and subjected to a tube inspection.

c.

The tubes selected as the second and third samples (if required by Table 6.5.9-2) during each inservice inspection may be subjected to a partial inspection provided:

1.

The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously found.

2.

The inspections include those portions of the tubes where imperfections were previously found.

ARKANSAS - UNIT 2 6-8 Amendment No.

ADMINISTRATIVE CONTROLS The result of each sample inspection shall be classified into one of the following three categories:

Category Inspection Results C-1 Less than 5% of the total tubes inspected are degraded tubes and none of the inspected tubes are defective.

C-2 One or more tubes, but not more than 1% of the total tubes inspected are defective, or between 5% and 10% of the total tubes inspected are degraded tubes.

C-3 More than 10% of the total tubes inspected are degraded tubes or more than 1% of the inspected tubes are defective.

Note: In all inspections, previously degraded tubes must exhibit significant (>10%) further wall penetrations to be included in the above percentage calculations.

ARKANSAS - UNIT 2 6-9 Amendment No.

ADMINISTRATIVE CONTROLS TABLE 6.5.9-2 STEAM GENERATOR TUBE INSPECTION 1ST SAMPLE INSPECTION 2ND SAMPLE INSPECTION 3RD SAMPLE INSPECTION Sample Size Result Action Required Result Action Required Result Action Required A minimum C-1 None N/A N/A N/A N/A of S Tubes per S.G.

C-2 Plug defective tubes C-1 None NIA NIA and Inspect additional I

2S tubes In this S.G.

C-2 Plug defective tubes C-1 None and Inspect additional 4S tubes C-2 Plug defective tubes In this S5G.

C-3 Perform action for C-3 result of first sample C-3 Perform action for NIA N/A C-3 result of first sample C-3 Inspect all tubes In Other None NIA N/A this S.G., plug S.G. Is defective tubes and C-1 Inspect 2S tubes In the other S.G.

Special Report to Other Perform action for N/A N/A NRC per Specification S.G. Is C-2 result of second 6.6.7 C-2 sample Other Inspect an tubes In N/A N/A S.G. Is the other S.G. and C-3 plug defective tubes.

Special Report to NRC per Spec. 6.6.7 S = 3 (2/n) % Where n is the number of steam generators inspected during an inspection.

ARKANSAS - UNIT 2 6-13 Amendment No.

ADMINISTRATIVE CONTROLS 6.5.10 Secondary Water Chemistry This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points;

d.

Procedure for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data, and the sequence and timing of administrative events required to initiate corrective action.

ARKANSAS - UNIT 2 6-14 Amendment No.