ML042720521

Issuance of Amendment Revisions on Administrative Controls

ML042720521
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/28/2004
From:	Alexion T NRC/NRR/DLPM/LPD4
To:	Forbes J Entergy Operations
Alexion T W, NRR/DLPM, 415-1326
References
TAC MB9887
Download: ML042720521 (25)

Text

September 28, 2004 Mr. Jeffrey S. Forbes Site Vice President Arkansas Nuclear One Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: REVISION OF ADMINISTRATIVE CONTROLS (TAC NO. MB9887)

Dear Mr. Forbes:

The Commission has issued the enclosed Amendment No. 255 to Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit No. 2 (ANO-2). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 30, 2003, as supplemented by letters dated November 20, 2003, February 27, 2004, and September 10, 2004.

The amendment (1) reorganizes the ANO-2 TS Section 6.0, Administrative Controls, (2) modifies the ANO-2 Facility Operating License, and Actions and Surveillance Requirements (SRs) of various other TSs, to support the reorganization of Section 6.0, and (3) modifies several Actions and SRs that are related to systems that are shared by ANO-2 and Arkansas Nuclear One, Unit No. 1.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

Thomas W. Alexion, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosures:

1. Amendment No. 255 to NPF-6

2. Safety Evaluation cc w/encls:

See next page

September 28, 2004 Mr. Jeffrey F. Forbes Site Vice President Arkansas Nuclear One Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: REVISION OF ADMINISTRATIVE CONTROLS (TAC NO. MB9887)

Dear Mr. Forbes:

The Commission has issued the enclosed Amendment No. 255 to Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit No. 2 (ANO-2). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 30, 2003, as supplemented by letters dated November 20, 2003, February 27, 2004, and September 10, 2004.

The amendment (1) reorganizes the ANO-2 TS Section 6.0, Administrative Controls, (2) modifies the ANO-2 Facility Operating License, and Actions and Surveillance Requirements (SRs) of various other TSs, to support the reorganization of Section 6.0, and (3) modifies several Actions and SRs that are related to systems that are shared by ANO-2 and Arkansas Nuclear One, Unit No. 1.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Docket No. 50-368 Sincerely,

/RA/

Enclosures:

1. Amendment Thomas W. Alexion, Project Manager, Section 1 No. 255 to NPF-6 Project Directorate IV

2. Safety Evaluation Division of Licensing Project Management cc w/encls:

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Accession No.:ML042720521(Letter)

• SE input date, **agrees with deletion of LTOP reporting, ***See previous concurrence OFFICE PDIV-1/PM PDIV-1/LA IROB/SC SRXB/SC OGC PDIV-1/SC(A)

NAME TAlexion DJohnson TBoyce*

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SUttal(NLO)

M.Webb for R.Gramm DATE 9/16/04 9/16/04 8/18/04 9/14/04 9/27/04 9/28/04 OFFICIAL RECORD COPY

ENTERGY OPERATIONS, INC.

DOCKET NO. 50-368 ARKANSAS NUCLEAR ONE, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 255 License No. NPF-6 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Entergy Operations, Inc. (the licensee), dated June 30, 2003, as supplemented by letters dated November 20, 2003, February 27, 2004, and September 10, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-6 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 255, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA by M. Webb acting for/

Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: September 28, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 255 FACILITY OPERATING LICENSE NO. NPF-6 DOCKET NO. 50-368 Replace the following pages of the operating license with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

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8 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 255 TO FACILITY OPERATING LICENSE NO. NPF-6 ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT NO. 2 DOCKET NO. 50-368

1.0 INTRODUCTION

By application dated June 30, 2003 (ADAMS Accession No. ML031890906), as supplemented by letters dated November 20, 2003 (ADAMS Accession No. ML033290559), February 27, 2004 (ADAMS Accession No. ML040620499), and September 10, 2004 (ADAMS Accession No. ML042660143), Entergy Operations, Inc. (Entergy or the licensee), requested changes to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit No. 2 (ANO-2). The supplemental letters dated February 27 and September 10, 2004, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on December 9, 2003 (68 FR 68663).

The proposed changes would (1) reorganize the ANO-2 TS Section 6.0, Administrative Controls, (2) modify the ANO-2 Facility Operating License, and Actions and Surveillance Requirements (SRs) of various other TSs, to support the reorganization of Section 6.0, and (3) modify several Actions and SRs that are related to systems that are shared by ANO-2 and Arkansas Nuclear One, Unit No. 1 (ANO-1).

The proposed TS changes achieve consistency with corresponding requirements in the ANO-1 TSs, which are based on NUREG-1430, Standard Technical Specifications for Babcock &

Wilcox Plants, Revision 2, and NUREG-1432, Standard Technical Specifications for Combustion Engineering Plants, Revision 2, with exceptions to account for plant-specific design differences and retention of current licensing basis requirements and commitments. In addition to these requirements and considerations, the licensee based its proposed TS changes on the Commissions Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, (Final Policy Statement), published on July 22, 1993 (58 FR 39132),

and 10 CFR 50.36, Technical Specifications, as amended July 19, 1995 (60 FR 36953).

In this Safety Evaluation (SE), the staff refers to a current ANO-2 TS as a CTS; a standard TS, such as contained in NUREG-1432, as an STS; and a proposed ANO-2 TS, which results from changes addressed in this SE, as a PTS.

Consistent with the Final Policy Statement, the licensee proposed transferring some CTS requirements to licensee-controlled documents, such as the Safety Analysis Report (SAR) for ANO-2, for which changes are controlled by a regulation such as 10 CFR 50.59. Accordingly, if 10 CFR 50.59 does not require prior U.S. Nuclear Regulatory Commission (NRC) approval, such transferred requirements may be changed by the licensee without it. However, NRC-controlled documents, such as TSs, may not be changed by the licensee without prior NRC approval. In addition, the licensee emphasized human factors principles to add clarity to the CTS requirements being retained in the PTSs, and to more clearly define the appropriate scope of the PTSs.

During its review, the NRC staff relied on the Final Policy Statement, 10 CFR 50.36, the STSs, and ANO-1 TSs as guidance for accepting CTS changes. This SE provides a summary basis for the NRC staffs conclusion that the licensee has developed the PTSs based on the STSs and ANO-1 TSs, except for plant-specific considerations, and that the use of the PTSs are acceptable for continued operation of ANO-2. The SE also explains the NRC staffs conclusion that the PTSs are consistent with the ANO-2 current licensing basis and conform to 10 CFR 50.36. In this SE, staff conclusions regarding the conformance and consistency of the PTSs with these requirements are limited to specifications in the CTSs related to the specific changes proposed by the licensee in the subject application, as supplemented. The NRC staff also acknowledges that it is acceptable for the PTSs to differ from the STSs and ANO-1 TSs to retain CTS provisions, that are based on the current licensing basis for ANO-2, which the NRC staff has previously reviewed and approved.

For the reasons stated in this SE, the NRC staff finds that the PTSs issued with this license amendment comply with Section 182a of the Atomic Energy Act, as amended, 10 CFR 50.36, and the guidance in the Final Policy Statement, and that they are in accordance with the common defense and security and provide adequate protection of the health and safety of the public.

2.0 REGULATORY EVALUATION

Section 182a of the Act requires that applicants for nuclear power plant operating licenses will state:

[S]uch technical specifications, including information of the amount, kind, and source of special nuclear material required, the place of the use, the specific characteristics of the facility, and such other information as the Commission may, by rule or regulation, deem necessary in order to enable it to find that the utilization... of special nuclear material will be in accord with the common defense and security and will provide adequate protection to the health and safety of the public. Such technical specifications shall be a part of any license issued.

In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TSs. In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and the mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TSs those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity, as set forth in Statement of Consideration, Technical Specifications for Facility Licenses; Safety Analysis Reports, (33 FR 18610, December 17, 1968). Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls.

However, the rule does not specify the particular requirements to be included in a plants TSs.

NRC and industry representatives have developed guidelines for improving the content and quality of nuclear power plant TSs. On February 6, 1987, the Commission issued an interim policy statement on TS improvements, Interim Policy Statement on Technical Specification Improvements for Nuclear Power Reactors (52 FR 3788). During the period from 1989 to 1992, the utility owners groups and the NRC staff developed improved STSs, such as NUREG-1432, that would establish model TSs consistent with the Commissions policy for each primary reactor, nuclear steam supply system, type. In addition, the NRC staff, licensees, and owners groups developed generic administrative and editorial guidelines in the form of a Writers Guide for preparing TSs, which gives greater consideration to human factors principles. Entergy followed this guidance in the development of the TS changes proposed in the subject application for ANO-2.

In April 2001, the Commission issued NUREG-1432, Revision 2, which was developed using the guidance and criteria contained in the Commissions Interim Policy Statement. The improved STSs in NUREG-1432 were established as a model for developing improved TSs for Combustion Engineering plants in general. The improved STSs reflect the results of a detailed review of the application of the interim policy statement criteria to generic system functions, which were published in a Split Report issued to the nuclear steam supply system owners groups in May 1988. The improved STSs also reflect the results of extensive discussions between the owners groups and the staff concerning a number of drafts and revisions, so that application of the Writers Guide and the TS content criteria in 10 CFR 50.36 would consistently reflect detailed system configurations and operating characteristics for all nuclear steam supply system designs. As such, the improved STS Bases presented in NUREG-1432 provide an abundance of generally applicable information regarding the extent to which NUREG-1432 presents requirements that are necessary to protect public health and safety. With respect to the subject application, Section 5.0, Administrative Controls, in NUREG-1432 applies to ANO-2.

On July 22, 1993, the Commission issued its Final Policy Statement, expressing the view that satisfying the guidance in the policy statement also satisfies Section 182a of the Act and 10 CFR 50.36 (58 FR 39132). The Final Policy Statement described the safety benefits of the improved STSs, and encouraged licensees to use the improved STSs as the basis for plant-specific license amendments. The scope of such amendments that are based on the STSs range from partial conversions involving changes to one or more individual specifications, to complete conversions of a plants TSs. The subject application for ANO-2 proposes a partial conversion of the ANO-2 CTSs related to administrative controls. Further, the Final Policy Statement gave guidance for evaluating the required scope of a plants TSs and defined four guidance criteria to be used in determining which existing TS LCO requirements, including any associated Action and SRs, should remain in the TSs. The Commission noted that, in allowing certain items to be relocated to licensee-controlled documents while requiring that other items be retained in the TSs, it was adopting the qualitative standard enunciated by the Atomic Safety and Licensing Appeal Board in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979). There, the Appeal Board observed:

[T]here is neither a statutory nor a regulatory requirement that every operational detail set forth in an applicants safety analysis report (or equivalent) be subject to a technical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval. Rather, as best we can discern it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.

By this approach, existing LCO (and associated) requirements that fall within or satisfy any of the criteria in the Final Policy Statement should be retained in the TSs; those LCO (and associated) requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. The Commission codified the four criteria set out in the Final Policy Statement in 10 CFR 50.36(c)(2)(ii) (60 FR 36953, July 19, 1995). The four criteria are as follows:

Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room (CR), a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a design basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3 A structure, system, or component (SSC) that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4 A SSC which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Part 3.0 of this SE provides the basis for the NRC staffs conclusion that the conversion of various sections of ANO-2 CTSs to PTSs based on corresponding requirements in the STSs and the ANO-1 TSs, as modified by plant-specific considerations, is consistent with the ANO-2 current licensing bases and the requirements and guidance of the Final Policy Statement and 10 CFR 50.36.

3.0 TECHNICAL EVALUATION

The NRC staff has organized this SE by identifying each proposed TS change as belonging to one of the following TS change categories:

A Administrative A change that neither reduces nor increases the existing operational limitations and administrative controls for the facility.

M More Restrictive A change that increases an existing operational limitation or administrative control, or that adds a new operational limitation or administrative control for the facility.

L Less Restrictive A change that reduces or deletes an existing (Specific) operational limitation or administrative control for the facility.

LA Less Restrictive A change that involves moving detailed technical (Generic) information or requirements, which are inappropriate or unnecessary for inclusion in TSs, to licensee-controlled documents.

Grouping TS changes in these four categories is customary for evaluating applications that propose to convert a facilitys TSs to improved TSs, modeled on the STSs. The NRC staff chose this approach for this review because of the number of changes proposed and the similarity of the resulting TS requirements to corresponding provisions in the STSs.

In its application, the licensee assigned each CTS change a discussion of change (DOC) number indicating the change type with the prefix of A, M, L, or LA. The licensee described each change and stated its justification in the associated DOC. The tables attached to this SE describe all the changes to the CTSs by change type and DOC number. The following subsections provide detailed discussions of the CTS change categories, and the staffs evaluations of the acceptability of changes under each category.

3.1 Administrative Changes Administrative changes, which are incidental to adopting STS format or phrasing, are intended to incorporate human factors principles into the form and structure of the TSs making them easier to understand and use by plant operations personnel. These changes involve reorganizing, reformatting, and clarifying CTS requirements without affecting technical content or operational restrictions. Every specification in PTS Section 6.0 reflects this type of change.

In order to ensure consistency, the NRC staff and the licensee have followed corresponding STS Section 5.0 and ANO-1 TS Section 5.0 as guidance for making administrative changes in format. Among the administrative-type changes proposed by the licensee in the present application, and found acceptable by the NRC staff, are:

Providing appropriate CTS information, such as values for parameters and limits that must be supplied on a plant-specific basis and that may vary among plants, in place of STS bracketed information; Using plant-specific terms for names of SSCs; Deviating from the wording of specification titles in STSs to conform to existing plant nomenclature; Splitting up requirements currently grouped under a single specification in the CTSs to more appropriate locations in two or more specifications in the PTSs; Combining related requirements, currently presented in separate specifications of the CTSs, into a single specification in the PTSs; Rewording or reformatting presentation changes for clarity (including reorganizing existing requirements within the TSs) that does not involve changing operational requirements and restrictions; Making wording changes and additions that are consistent with established interpretations and practices to more clearly or explicitly state the NRC staff-accepted intent of CTS requirements; Deleting redundant statements of requirements that are specified in more than one location in the CTSs; and Correcting typographical, spelling, and grammatical errors in CTSs.

Table A lists the administrative changes incorporated in the PTSs. For each numbered DOC, Table A provides a summary description of the administrative change that was made, and references to the CTSs and PTSs involved in the change. The NRC staff reviewed all of the administrative changes proposed by the licensee and finds them acceptable because they are consistent with the Writers Guide, STSs, and ANO-1 TSs; do not result in any substantive change in operating requirements; and are consistent with the Commissions regulations.

3.2 More Restrictive Changes The licensee, in electing to implement the various specifications based on the STSs and the ANO-1 TSs, proposed a number of requirements that are more restrictive than those in the CTSs. PTSs in this category include requirements that are either new, more conservative than corresponding requirements in the CTSs, or that have additional restrictions that are not in the CTSs but are in the STSs and ANO-1 TSs. Examples of more restrictive requirements are additional qualification and position descriptions in plant personnel specifications and new programmatic specifications. Table M lists the more restrictive changes incorporated in the PTSs. For each numbered DOC, Table M provides a summary description of the more restrictive change that was made and references the affected CTSs and PTSs. Changes categorized as more restrictive are acceptable because they place additional limitations on plant operation that enhance safety.

3.3 Less Restrictive Changes (Specific)

Less restrictive requirements include changes, deletions, and relaxations to CTS requirements.

When requirements have been shown to give little or no safety benefit, their removal from the TSs may be appropriate. In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the owners groups comments during the development of the STSs. The NRC staff reviewed generic relaxations contained in the STSs and found them acceptable because they are consistent with current licensing practices and the Commissions regulations.

Less restrictive changes involved deletions and relaxations to CTS requirements and were evaluated under the following eight change categories.

I Relaxation of Surveillance Frequency II Relaxation of Action Requirements for Exiting LCOs III Relaxation of SR Acceptance Criteria IV Relaxation of Required Action and/or Completion Time V

Relaxation of LCOs VI Relaxation of the Administrative Requirements VII Elimination or Relaxation of CTS Reporting Requirements VIII Relaxation of CTS Requirements for High Radiation Areas The following discussions address why TS changes within each of these categories are acceptable.

Relaxation of Surveillance Frequency (Category I)

A facilitys TS SRs specify time interval requirements, or frequencies, for verifying that the plant is operating within specified parameter limits or for performing tests to verify that required systems are capable of performing their intended safety functions, i.e., that they are operable.

Increasing the time interval between performances of a surveillance for a specified SSC can enhance safety by increasing the SSCs overall availability (by decreasing the contribution of testing to the SSCs unavailability), while maintaining or increasing the SSCs reliability. In general, the STSs contain tests frequencies that are consistent with industry practice or industry standards for achieving acceptable levels of equipment reliability. Adoption of STS testing practices by plants is acceptable when justified on the basis of similar design, like-component testing for the system application, and the availability of other TS requirements that provide regular checks to ensure limits are met. Reduced testing is also acceptable when it is consistent with industry practice or industry standards, such as manufacturers recommendations, and when operating experience has shown that the specified SSC usually passes the surveillance when performed at the currently specified interval. In such cases, the relaxed surveillance frequency is acceptable because the expectation of no reduction in reliability of the equipment or component is adequately justified. In the present application (DOC 15), the licensee proposed to make the provisions of CTS 4.0.2 apply to the proposed 18-month surveillance test interval for performing integrated leak tests of systems outside containment that contain primary coolant, which is specified in PTS 6.5.2.b. The Bases for corresponding (and equivalent) STS SR 3.0.2 (which incorporates staff-approved Technical Specification Task Force (TSTF)-299) states:

SR 3.0.2 permits a 25% extension of the interval specified in the frequency. This extension facilitates surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the surveillance (e.g.,

transient conditions or other ongoing surveillance or maintenance activities).

The 25% extension does not significantly degrade the reliability that results from performing the surveillance at its specified frequency. This is based on the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the surveillance requirements.

On this basis, the staff finds that applying CTS 4.0.2 to PTS 6.5.2.b, which is consistent with STS 5.5.2, will not adversely impact the likelihood of detecting degradation of the boundary of a system containing reactor coolant outside containment. Therefore, changes designated as Category I are acceptable.

Relaxation of Action Requirements for Exiting LCOs (Category II)

In the event an LCO is not met, the associated action statements typically require, within specified time limits, initiating remedial measures to restore compliance with the LCO or establishing other appropriate operational limits or unit conditions. Failing these, the associated action statements require reducing unit power or shutting down the unit and placing it in an operational condition in which the LCO is not applicable, that is, not required to be met (i.e.,

exiting the LCO). Adopting STS action requirements for exiting LCOs is acceptable because the unit remains within analyzed parameters by performance of required actions, or the actions impose restrictions on unit operation that minimize risks associated with continued operation while providing time to repair inoperable features. Such actions assure that (a) the unit is configured appropriately or (b) operations that could result in a challenge to safety systems are exited in a time period that is commensurate with the safety importance of the inoperable SSC.

Additionally, the proposed changes to CTS actions for exiting LCOs are consistent with industry standards for reductions in thermal power in an orderly fashion without compromising safe operation of the unit. Therefore, changes designated as Category II are acceptable.

Relaxation of SR Acceptance Criteria (Category III)

The surveillances that verify component actuation on a test signal are revised to allow taking credit for an actual signal, such as from the engineered safety features actuation system instrumentation (e.g., in the event an actual signal is generated by an abnormal plant condition or system malfunction), as well as a simulated (i.e., test) signal, for meeting the SR acceptance criteria. This is acceptable because the end device cannot distinguish between an actual and simulated signal. Changes like this have no impact on the validity of such surveillances, but do provide flexibility in meeting them.

Where the scope of tests specified by a SR, and the associated acceptance criteria, have exceeded what is necessary to demonstrate and assure operability of a required SSC, the STSs have reduced the scope. An ANO-2 example of such a surveillance is the testing required of the diesel fuel oil from the diesel fuel storage tanks. CTS 4.8.1.1.2.b requires checking that the fuel oil is within the acceptable limits specified in Table 1 of American Society for Testing and Materials (ASTM)-D975-74 when checked for viscosity, water and sediment.

Corresponding PTSs 4.8.1.3.2 and 6.5.13.c will require the periodic testing of stored fuel for particulates only, consistent with STS 5.5.13.c. In its application, the licensee stated:

This change reflects industry standard acceptable diesel generator (DG) fuel oil testing programs reflected in NUREG-1432. Over the storage life of ANO-2 fuel oil, the properties tested by ASTM-D975 are not expected to change and performing these tests once on the new fuel oil...provides adequate assurance of the proper quality fuel oil. The periodic testing for particulates monitors a parameter that reflects degradation of fuel oil and can be trended to provide increased confidence that the stored DG fuel oil will support DG operability.

The NRC staff has previously accepted this basis for reducing the scope of diesel fuel oil testing, as documented by STS 5.5.13 requirements and the Bases for STS SR 3.8.3.3.

The staff finds that crediting actual actuation signals and reducing the scope of testing, when appropriate, will not adversely impact plant safety. Therefore, changes identified as Category III are acceptable.

Relaxation of Required Action and/or Completion Time (Category IV)

Upon discovery of a degraded or nonconforming condition (e.g., an inoperable subsystem or a specified parameter outside normal limits) that results in a failure to meet a TS LCO, the licensee must perform the required actions specified for each applicable condition of the LCOs associated action requirements table. The licensee must perform these actions within the specified required action completion times. If the licensee does not resolve the degraded condition within the specified completion time for restoring operability (the allowed outage time) or for returning the specified parameter to within limits, or fails to perform any other remedial action specified for the condition within the specified completion time, the LCOs associated action requirements usually require placing the unit in a condition that is outside the LCOs mode of applicability (typically, a unit shutdown) on a schedule defined by the associated specified completion times. The STSs contain standard completion times that are specified for similar conditions. For example, STSs specify 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for restoring redundancy of a 2-train system, and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for placing the unit in Cold Shutdown (Mode 5).

Adopting completion times from the STSs is acceptable because standard completion times take into account the operability status of the redundant systems of TS required features, the capacity and capability of remaining features, a reasonable time for repair or replacement of required features, and the low probability of a DBA occurring during the repair period. These reasons apply to the relaxation of ANO-2 CTS required action completion times proposed in the present application. The staff finds that these changes are consistent with STSs and will not adversely impact plant safety. Therefore, changes identified as Category IV are acceptable.

Relaxation of LCOs (Category V)

CTSs contain LCOs that are overly restrictive because they specify limits on operational and system parameters and on system operability beyond those necessary to meet safety analysis assumptions. CTSs also contain administrative controls that do not contribute to the safe operation of the plant. STSs omit such operational limits and administrative controls. In addition, STSs contain exceptions to operational restrictions imposed by LCOs when such exceptions do not adversely impact safety and are of practical necessity. One example of such exceptions in the present application is the addition of an LCO note that allows intermittent opening of the CR boundary under administrative controls (consistent with staff-approved TSTF-287). This note explicitly clarifies that momentarily opening the CR boundary, such as when opening a door, is acceptable provided appropriate administrative control of the opening is maintained by licensee staff. This change is discussed in more detail in Section 3.5 of this SE. Another example is adding a note to allow time to perform a channel functional test (CFT) of the automatic initiation of CR emergency ventilation on a ventilation intake radiation monitor signal, before taking specified action requirements. This note effectively extends the associated completion times for the applicable required actions. Conduct of this CFT renders the instrumentation inoperable, but must be accomplished when CTSs require the monitor to be operable. However, performance of the test is not possible while complying with the associated action requirements, which specify running the system. The proposed delay in taking the specified actions is sufficient to perform the CFT, which provides assurance of the instrumentations operability, while appropriately limiting the duration of unit operation with a loss of functional redundancy. The staff finds that the LCOs modified by these notes will allow necessary operational flexibility without adversely affecting the safe operation of the unit.

Therefore, changes designated as Category V are acceptable.

Relaxation of the Administrative Requirements (Category VI)

CTS 6.2.2.c and Table 6.2-1 is modified to add the requirement that the position of radiation protection technicians and shift technical advisor (STA) may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the require position. The purpose of this new requirement statement is to provide wording consistent to that of the STSs. The addition of this requirement statement provides the same accommodation for unexpected absences contained in other specifications of CTS Section 6.2.2 for radiation protection technicians and the STA. This proposed change is consistent with the NRC interpretation of implementing 10 CFR 50.54(m)(2)(i). This change is less restrictive because it provides an accommodation of absence up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that did not previously apply to the these positions. Another relaxation is explicitly requiring the STA to support the shift crew instead of just the shift supervisor. This provides more flexibility to the STA and the crew and is consistent with the actual practice of the STA at ANO-2.

CTS 6.7.1.b requires notification of the Vice President, Operations ANO within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of violating a safety limit. This notification is administratively controlled as part of the ANO corrective action process, which is required by CTS 6.4.1 and the ANO Quality Assurance program. The staff finds that these requirements are adequate to ensure timely notification of licensee management of unit operational problems and events, including safetry limit violations.

However, management notification following a safety limit violation occuring does not provide assurance of safe unit operation. Deleting this redundant notification requirement is, therefore, acceptable.

The staff finds that relaxations of administrative requirements regarding unit staffing vacancies and licensee management notification will not adversely impact safe operation of the unit.

Therefore, changes designated as Category VI are acceptable.

Elimination or Relaxation of CTS Reporting Requirements (Category VII)

The reporting of safety and relief valve failures and challenges is based on the guidance in NUREG-0694, TMI-Related Requirements for New Operating Licensees. The guidance of NUREG-0694 states:

Assure that any failure of a PORV (power operated relief valve) or safety valve to close will be reported to the NRC promptly. All changes to the PORVs or safety valves should be documented in the annual report.

In addition, ANO-2 Amendment 180 (dated March 7, 1997) stated that the periodic safety valve report was to include challenges to the Low Temperature Overpressure Protection (LTOP) valves. (There are no PORVs at ANO-2). NRC Generic Letter 97-02, Revised Contents of the Monthly Operating Report, requested the submttal of less information in the monthly operating report. The generic letter identified the information licensees needed to report to support the NRC Performance Indicator Program. The generic letter did not specifically identify reporting challenges to the pressurizer safety valves or the LTOP valves. The NRC staff concluded that this information is not required for the Performance Indicator Program and therefore would not need to be reported. Based on this information, it is acceptable to delete the TS requirement to provide documentation in the annual report of all challenges to pressurizer safety valves.

Similarly, withdrawal of the commitment to report LTOP challenges is acceptable. Thus, these reporting requirements can be deleted with no adverse affect on the safe operation of the plant.

The licensee proposed to revise the due dates for the annual Occupational Radiation Exposure Report and the Radiological Effluent Release Report from March 1 to April 30, and from March 1 to May 1, respectively. These changes have no impact on the safety of unit operations and conform to the due dates for the ANO-1 reports.

The proposed deletion and relaxations of these CTS reporting requirements do not adversely impact safe operation of the unit. Therefore, changes designated as Category VII are acceptable.

Relaxation of CTS Requirements for High Radiation Areas (Category VIII)

The requirements for high radiation areas in CTS 6.13 will be revised to include additional previously approved methods for implementation of alternates to the control device or alarm signal requirements of 10 CFR 20.1601(a)(2). These alternatives provide adequate control of personnel in high radiation areas and are consistent with STS Section 5.7. Therefore, changes designated as Category VIII are acceptable.

Summary Conclusion for Less Restrictive Changes (Specific)

Table L lists all CTS requirements that have been relaxed and which pertain to the 8 Categories of specific less restrictive changes discussed above. For each change, Table L includes the DOC number, a summary description, CTS and PTS references, and a reference to the applicable L-type change categories.

For the reasons presented above, these less restrictive requirements are acceptable because they will not affect the safe operation of the unit. The revised TS requirements are consistent with current licensing practices and operating experience, and provide reasonable assurance that public health and safety will be protected.

3.4 Less Restrictive Changes (Generic) (Removal of Details)

When requirements have been shown to give little or no benefit, their removal from the TSs may be appropriate. In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the owners group comments on STSs. The NRC staff reviewed generic relaxations contained in the STSs and found them acceptable because they are consistent with current licensing practices and the Commissions regulations. A number of changes to the CTSs involved the removal of specific requirements and detailed information from individual specifications and were evaluated to be Types 1 thru 3, described below:

Type 1 - Details of System Design and System Description Including Design Limits Type 2 - Procedural Details for Meeting TS Requirements and Related Reporting Requirements Type 3 - Relocated Administrative Control Requirements The following discussions address why each of the three types of information or specific requirements are not required to be included in TSs.

Details of System Design and System Description Including Design Limits (Type 1)

The design of the facility is required to be described in the SAR by 10 CFR 50.34. In addition, the quality assurance (QA) requirements of Appendix B to 10 CFR Part 50 require that plant design be documented in controlled procedures and drawings, and maintained in accordance with an NRC-approved QA plan (referenced in the SAR). In 10 CFR 50.59, controls are specified for changing the facility as described in the SAR, and in 10 CFR 50.54(a), criteria are specified for changing the QA plan. In the STSs, the Bases also contain descriptions of system design. STS 5.5.14 and PTS 6.5.14 specify controls for changing information in the TS Bases.

Removing details of system design from the CTSs is acceptable because this information will be adequately controlled in the SAR, controlled design documents and drawings, or the PTS Bases, as appropriate.

Procedural Details for Meeting TS Requirements and Related Reporting Requirements (Type 2)

Details for performing action and SRs are more appropriately specified in the plant procedures required by PTS 6.4.1, the SAR, and the PTS Bases. For example, control of the plant conditions appropriate to perform a surveillance test is an issue for procedures and scheduling, and has previously been determined to be unnecessary as a TS restriction. As indicated in Generic Letter 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," allowing this procedural control is consistent with the vast majority of other SRs that do not dictate plant conditions for surveillances. Prescriptive procedural information in an action requirement is unlikely to contain all procedural considerations necessary for the plant operators to complete the actions required, and referral to plant procedures is therefore required in any event. Other changes to procedural details include those associated with limits retained in the PTSs. The removal of these kinds of procedural details from the CTSs is acceptable because they will be adequately controlled in the SAR and Bases, as appropriate. This approach provides an effective level of regulatory control and provides for a more appropriate change control process.

Similarly, removal of reporting requirements from LCOs is appropriate because PTS 6.6, 10 CFR 50.36, and 10 CFR 50.73 adequately cover the reports needed by the NRC staff. In addition, some of the reports currently specified in CTS administrative control requirements are also unnecessary. Consistent with the STSs, the requirement of CTSs 6.9.1.1, 6.9.1.2, and 6.9.1.3 to submit a startup report to the NRC is being moved to the Technical Requirements Manual (TRM). The staff finds that this report does not contribute to safe operation of the facility because it is submitted following unit startup. Maintaining this reporting requirement in the TRM will ensure that the activities associated with the preparation of this report are adequately performed and that appropriate corrective actions, if required, are taken. Therefore, removing reporting requirements is acceptable.

Relocated Administrative Control Requirements (Type 3)

A number of CTS requirements specify a level of detail beyond what is required to be specified in the TSs to ensure that the plant is operated in a safe manner. The details are administrative in nature (e.g., facility staff position titles) and therefore do not effect the safe operation of the plant. It is not necessary to include this type of information in the TSs to provide adequate protection of public health and safety, because these types of administrative details are contained in controlled programs and maintained pursuant to 10 CFR 50.54, 10 CFR 50.59, and Appendix B of 10 CFR Part 50, which ensure that the changes are properly evaluated. The removal of these kinds of administrative details from the CTSs is acceptable because they will be adequately controlled and this approach provides an effective level of regulatory control and a more appropriate change control process.

Summary Conclusion for Less Restrictive Changes (Generic)

Table LA describes the detailed information removed from individual CTSs and placed in licensee-controlled documents. In addition, Table LA states the associated DOC, the CTS reference, the name of the licensee-controlled document that retains the removed information, details, or requirements; the method for controlling future changes to the removed requirements; and a reference to the specific change type, as discussed above, to indicate the basis for not including the information or specific requirements in the ANO-2 TSs.

The NRC staff has concluded that these types of detailed information and specific requirements are not necessary to ensure the effectiveness of the ANO-2 TSs to adequately protect the health and safety of the public. Accordingly, these requirements may be moved to one of the following licensee-controlled documents for which changes are adequately governed by a regulatory or TS requirement: (1) SAR controlled by 10 CFR 50.59; (2) TRM controlled by 10 CFR 50.59; (3) Site Procedures controlled by 10 CFR 50.59; (4) ANO-2 Bases controlled by the TS Bases Control Program (PTS 6.5.14); and (5) QA plans as approved by the NRC and referenced in the SAR and controlled by 10 CFR Part 50, Appendix B, and 10 CFR 50.54(a).

To the extent that requirements and information have been relocated to licensee-controlled documents, such information and requirements are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.

Further, where such information and requirements are contained in LCOs and associated requirements in CTS 6.0, the NRC staff has concluded that they do not fall within any of the four criteria in 10 CFR 50.36(c)(2)(ii). Accordingly, existing detailed information and specific requirements, such as generally described above, may be removed from the CTSs.

3.5 TSTF-287 (DOC L3) L-type Change Categories II, IV, and V Current TS 3/4.7.6.1, Control Room Emergency Ventilation and Air Conditioning System, specifies no explicit action requirements in the event both Control Room Emergency Ventilation System (CREVS) trains are inoperable due to an inoperable CR boundary. In this condition, the CTSs would require a unit shutdown in accordance with LCO 3.0.3. Thus CTSs do not provide sufficient time to effect repairs or corrective maintenance of the CR boundary before requiring a plant shutdown.

A utilities owners group recognized that the improved STSs were inconsistent with regard to the remedial measures to be taken when breaching various ventilation controlled boundaries. For example, NUREG-1433 Specification 3.6.4.1 for the secondary containment allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the secondary containment envelope to operable status before requiring an orderly shutdown from operating conditions. In response, the owners group-established TSTF proposed a generic change to the STSs (NUREG-1430 through 1434) to resolve such inconsistencies. The proposed change, or TSTF, (a) revised the action requirements to allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable CR boundary to operable status, and (b) added a note to the CR emergency filtration ventilation system LCO to permit intermittent opening of the CR boundary under administrative control. This LCO note addresses routine operations such as normal entry and egress, and other minor evolutions that result in a short-term loss of CR boundary integrity. Included with the associated changes to the STS Bases is a reviewers note for adopting the proposed action requirement for the condition of an inoperable CR boundary.

According to this reviewers note, approval of the 24-hour Completion Time to restore an inoperable CR boundary is contingent upon a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into this condition. The proposed LCO note and action requirement were deemed acceptable because of (a) the small probability of a DBA requiring CR filtration occurring during the brief periods that the CR boundary would be intentionally open under administrative control and during the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed to restore the CR boundary to operable status, and (b) procedural requirements for compensatory measures, which are consistent with the intent of General Design Criterion (GDC) 19 and administrative controls.

The staff approved the requested STS changes as TSTF-287, Rev. 5, which were incorporated in Specification 3.7.11, Control Room Emergency Air Cleanup System (CREACS), of NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Rev. 3.

These changes to Specification 3.7.11 are applicable to corresponding ANO-2 CTS 3/4.7.6.1.

Consistent with the STSs, the LCO, TS 3.7.6.1, is modified by a Note (Note 1) allowing the CR boundary to be opened intermittently under administrative controls. As part of adopting Note 1, the licensee made a commitment to require that (1) for entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area, and (2) for other openings, the administrative control consists of stationing an individual at the opening who is in continuous communication with the CR. This dedicated individual will have a method to rapidly close the opening when a need for CR area isolation is indicated.

If the CR boundary is inoperable in Modes 1, 2, 3, or 4, such that the two CREVS trains are inoperable, action must be taken to restore an operable CR boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24-hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period and compensatory measures available to the operator to minimize the consequences of potential hazards.

The proposed Action d would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (during Modes 1, 2, 3, or 4) to restore the capability to maintain CR boundary pressure before requiring the unit to perform an orderly shutdown. The LCO note would allow intermittent opening of the CR boundary under administrative control, without requiring entry into new Action b. In its submittal, the licensee made a commitment, consistent with the reviewers note of TSTF-287, that during the period that the CR boundary is inoperable, appropriate compensatory measures consistent with the intent of GDC 19 will be utilized to protect the CR operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature, and relative humidity, and to ensure physical security. These preplanned measures will be available to address these concerns for intentional and unintentional entry into the condition. For example, when the CR boundary is opened for other than entry through doors, the proposed Bases discuss, in addition to other necessary measures, stationing a dedicated individual in the area who is in continuous contact with the CR to rapidly restore the boundary.

In addition to the licensees commitment to establish and implement appropriate administrative controls and necessary compensatory measures, the proposed changes are acceptable because of the low probability of an event requiring an intact CR boundary during the 24-hour Completion Time associated with Action d. In addition to Action d, the licensee proposed new Action e (and renumbered existing Actions d, e, f, and g as Actions f, g, h, and i, which are specified for during handling of irradiated fuel). Proposed Action e explicitly states the existing TS requirement to enter Specification 3.0.3 in the event two CREVS trains are inoperable for other than Action d. This is an administrative change that was made necessary by the addition of Action d, and is therefore acceptable.

Based on the low probability of a DBA occurring during the brief time allowed for the CR boundary to be inoperable, the availability of compensatory measures consistent with GDC 19 to minimize the consequences should a DBA occur, and conformance with TSTF-287 and the STSs, the proposed changes to CTS 3/4.7.6.1 are acceptable.

3.6 ANO-2 TS Bases The licensee proposed conforming changes to the Bases for the specifications revised in this amendment. The NRC staff has no objection to these Bases changes.

4.0 REGULATORY COMMITMENTS The licensees supplemental letters dated November 20, 2003, and September 10, 2004, contained the following regulatory commitments:

COMMITMENT TYPE (Check one)

SCHEDULED COMPLETION DATE (If Required)

ONE-TIME ACTION CONTINUING COMPLIANCE The details of the Diesel Fuel Oil Testing Program (DFOTP) and the details of the Ventilation Filter Testing Program (VFTP) will be maintained in site procedures.

X Upon implementation The details of design or process which are not directly pertinent to the actual requirement, i.e., Definition, Limiting Condition for Operation, or Surveillance Requirement, but rather describe additional unnecessary details such as an acceptable method of compliance will be relocated as follows:

CTS Location New Location FOL 2.c.(6) SAR 4.7.6.1.2.a Bases, SR 4.7.6.1.2.a 4.7.6.1.2.d.2 Bases, SR 4.7.6.1.2.b 6.9.1.1 TRM 6.9.1.2 TRM 6.9.1.3 TRM X

Upon implementation Compliance details relating to the plant specific management position titles fulfilling the duties of generic positions will continue to be defined, established, documented, and updated in the ANO-2 Safety Analysis Report (SAR).

X Written procedures will be established to describe the administrative controls and compensatory measures as stated in the Technical Specification Bases of proposed Note 1 and Action d of Specification 3.7.6.1, respectively.

X Upon implementation The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are best provided by the licensees administrative processes, including its commitment management program. The above regulatory commitments do not warrant the creation of a regulatory requirement (item requiring prior NRC approval of subsequent changes).

5.0 EVALUATION

SUMMARY

The ANO-2 TSs revised in this amendment provide clearer, more readily understandable requirements to ensure safe operation of the plant. The NRC staff concludes that they satisfy the guidance in the Commissions policy statement with regard to the content of TSs, and conform to the model format provided in NUREG-1432, Section 5.0, with appropriate modifications for plant-specific considerations. The NRC staff further concludes that the proposed ANO-2 TSs satisfy Section 182a of the Act, 10 CFR 50.36, and other applicable standards. On this basis, the NRC staff concludes that the proposed changes to the ANO-2 TSs are acceptable.

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Arkansas State official was notified of the proposed issuance of the amendment. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published December 9, 2003 (68 FR 68663). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

8.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: C. Harbuck Date: September 28, 2004 Attachments: Table A - Administrative Changes Table M - More Restrictive Changes Table LA - Relocated Specifications and Removal of Details Table L - Less Restrictive Changes

July 2004 Arkansas Nuclear One cc:

Senior Vice President

& Chief Operating Officer Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 Mr. Mike Schoppman Framatome ANP 3815 Old Forest Road Lynchburg, VA 24501 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 Vice President, Operations Support Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205