ML081400445

Issuance of Amendment No. 280 Reactor Coolant System Relocation to TRM (Tac MD8313)

ML081400445
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/23/2008
From:	Wang A NRC/NRR/ADRO/DORL/LPLIV
To:	Entergy Operations
Wang, A B, NRR/DORL/LPLIV, 415-1445
Shared Package
ML081400227	List: ML081400445 ML081400449
References
TAC MD8313
Download: ML081400445 (10)

Text

July 23, 2008 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT NO. 2 - ISSUANCE OF AMENDMENT RE:

TECHNICAL SPECIFICATION 3.4.7, REACTOR COOLANT SYSTEM CHEMISTRY (TAC NO. MD8313)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 280 to Renewed 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 March 13, 2008, as supplemented by letter dated July 1, 2008.

The amendment relocates TS 3.4.7, Reactor Coolant System Chemistry, to the Technical Requirements Manual (TRM). The change is consistent with the NUREG 1432, Standard Technical Specifications for Combustion Engineering Plants. The amendment also corrects an editorial and a typographical error on TS Page 3/4 4-14b.

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

Sincerely,

/RA/

Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosures:

1. Amendment No. 280 to NPF-6

2. Safety Evaluation cc w/encls: See next page

July 23, 2008 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT NO. 2 - ISSUANCE OF AMENDMENT RE:

TECHNICAL SPECIFICATION 3.4.7, REACTOR COOLANT SYSTEM CHEMISTRY (TAC NO. MD8313)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 280 to Renewed 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 March 13, 2008, as supplemented by letter dated July 1, 2008.

The amendment relocates TS 3.4.7, Reactor Coolant System Chemistry, to the Technical Requirements Manual (TRM). The change is consistent with the NUREG 1432, Standard Technical Specifications for Combustion Engineering Plants. The amendment also corrects an editorial and a typographical error on TS Page 3/4 4-14b.

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

Sincerely,

/RA/

Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosures:

1. Amendment No. 280 to NPF-6

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC RidsNrrDorlLpl4 GHill, OIS (2)

LPLIV R/F RidsNrrLAGLappert RidsAcrsAcnw&wMailCenter RidsNrrPMAWang RidsNrrDirsItsb RidsOgcRp RidsNrrDorlDpr RidsRgn4MailCenter ADAMS Accession No.: Pkg ML081400227 (Amdt ML081400445, License/TS Pgs ML081400449)

OFFICE NRR/LPL4/PM NRR/LPL4/LA DIRS/ITSB/BC OGC NRR/LPL4/BC (A) NRR/LPL4/PM NAME AWang GLappert RElliott SBrock, NLO MThadani AWang DATE 6/2/08 6/2/08 6/10/08 6/20/08 7/22/08 7/23/08

3 Arkansas Nuclear One (6/10/08) cc:

Senior Vice President Section Chief, Division of Health Entergy Nuclear Operations Emergency Management Section P.O. Box 31995 Arkansas Department of Health and Jackson, MS 39286-1995 Human Services 4815 West Markham Street, Slot 30 Vice President, Oversight Little Rock, AR 72205-3867 Entergy Nuclear Operations P.O. Box 31995 Pope County Judge Jackson, MS 39286-1995 Pope County Courthouse 100 W. Main Street Senior Manager, Nuclear Safety Russellville, AR 72801

& Licensing Entergy Nuclear Operations Senior Resident Inspector P.O. Box 31995 U.S. Nuclear Regulatory Commission Jackson, MS 39286-1995 P.O. Box 310 London, AR 72847 Senior Vice President

& Chief Operating Officer Regional Administrator, Region IV Entergy Operations, Inc. U.S. Nuclear Regulatory Commission P.O. Box 31995 612 E. Lamar Blvd, Suite 400 Jackson, MS 39286-1995 Arlington, TX 76011 Associate General Counsel Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Manager, Licensing Entergy Operations, Inc.

Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Section Chief, Division of Health Radiation Control Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867

ENTERGY OPERATIONS, INC.

DOCKET NO. 50-368 ARKANSAS NUCLEAR ONE, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 280 Renewed 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 March 13, 2008, as supplemented by letter dated July 1, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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 Renewed 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. 280, are hereby incorporated in the renewed 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 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Mohan C. Thadani, Acting Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-6 Technical Specifications Date of Issuance: July 23, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 280 RENEWED FACILITY OPERATING LICENSE NO. NPF-6 DOCKET NO. 50-368 Replace the following pages of the Renewed Facility Operating License No. NPF-6 and 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.

Operating License REMOVE INSERT Page Page Technical Specifications REMOVE INSERT 3/4 4-14 3/4 4-14 3/4 4-14b 3/4 4-14b 3/4 4-15 -

3/4 4-16 -

3/4 4-17 -

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 280 TO RENEWED 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 March 13, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML080850907), as supplemented by letter dated July 1, 2008 (ADAMS Accession No. ML081850032), Entergy Operations, Inc. (Entergy, the licensee), requested changes to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit No. 2 (ANO-2).

The supplement dated July 1, 2008, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on May 6, 2008 (73 FR 25039).

The proposed changes would relocate the TS 3.4.7, Reactor Coolant System Chemistry, to the Technical Requirements Manual (TRM). The change is consistent with the NUREG 1432, Standard Technical Specifications for Combustion Engineering Plants. The proposed relocation results in several TS pages being deleted. A change to TS page 3/4 4-14b to state what the "next page is and a change to TS page 3/4 4-14 to correct a typographical error were proposed in support of the amendment.

2.0 REGULATORY EVALUATION

Reactor Coolant System (RCS) sampling and chemistry limits are discussed in various documents, such as NUREG 0737 and Regulatory Guide 1.97. However, there is no specific General Design Criteria (GDC) associated with RCS chemistry. The U.S. Nuclear Regulatory Commission (NRC) staff used the following NRC requirements to review the licensees amendment request:

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical Specifications,"

contains the requirements for items that must be in the TSs. Paragraph 50.36(d)(2)(ii) provides four criteria that can be used to determine the requirements that must be included in the TSs. A TS limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, 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 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 that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4. A structure, system, or component [SSC] which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Items not meeting any of these four criteria do not need to remain in the TSs.

3.0 TECHNICAL EVALUATION

TS 3.4.7 provides limits on the oxygen, chloride, and fluoride content in the RCS to minimize corrosion. Per the TS Bases, RCS chemistry parameters ensure that corrosion of RCS components is minimized, thus reducing the potential for RCS leakage or failure due to corrosion-based mechanisms. Maintaining the chemistry within limits provides adequate corrosion protection to ensure the structural integrity of the RCS over the life of the plant. RCS corrosion is a slow process which can be detected by in-service inspections or other means before significant degradation occurs. RCS chemistry is controlled to minimize corrosion over the long term.

Section 50.36 of 10 CFR, "Technical Specifications," contains the requirements for items that must be in the TSs. Paragraph 50.36(c)(2)(ii) provides four criteria that can be used to determine the requirements that must be included in the TSs. The NRC staff reviewed each item for meeting one or more of the four criteria for the need to be included in the TSs.

Criterion 1 addresses instrumentation installed to detect and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. This criterion does not apply since the RCS chemistry limits are not installed instrumentation that is used to detect excessive RCS leakage. Therefore, the RCS chemistry limits do not meet Criterion 1.

Criterion 2 captures those process variables that have initial values in the design-basis accident and transient analyses. The RCS chemistry limits are not a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, the RCS chemistry limits do not satisfy Criterion 2.

Criterion 3 captures only those SSCs that are part of the primary success path of the safety analysis (an examination of the actions required to mitigate the consequences of the design-basis accident and transients). The RCS chemistry limits are not a structure, system or component 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. Therefore, the RCS chemistry limits do not satisfy Criterion 3.

Criterion 4 captures those SSCs that either operating experience or probabilistic safety assessment has shown to be significant to the public health and safety. The RCS chemistry limits are not a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. As discussed in Section 4.0, (Appendix A, page A-40) of topical report WCAP- 11618 (Reference 1), the RCS chemistry limits were found to be a non-significant risk contributor to core damage frequency and offsite releases (WCAP-1 1618, "Criteria Application," evaluated Limiting Conditions for Operation (LCOs) contained in TSs for Westinghouse pressurized water reactors with respect to the criteria of 10 CFR 50.36 to determine which LCOs satisfied any of the criteria). In addition to the above, the RCS chemistry limits are not important for any scenarios modeled in the ANO-2 safety analyses. Therefore, the RCS chemistry limits do not meet Criterion 4.

The NRC staff notes that although it is important to monitor and control RCS chemistry, it has concluded that the limits and surveillance requirements for RCS chemistry in TS 3.4.7 do not meet the criteria of 10 CFR 50.36 for inclusion in the TSs. Therefore, the NRC staff concludes that the licensee has demonstrated that the relocation of limits on the oxygen, chloride, and fluoride content in the RCS to minimize corrosion from the TSs to the TRM is acceptable. In addition, plant-specific TSs relating to RCS chemistry were not included in the original version of the NUREG 1432 because RCS chemistry limits did not meet the TS inclusion requirements of 10 CFR 50.36. Therefore, this change is consistent with NUREG 1432.

As TS pages 3/4 4-15, 16, and 17 were deleted, a note was added on page 3/4 4-14 to note that the next page is 3/4 4-18. By letter dated July 1, 2008, the licensee noted that two sequential pages 3/4 4-14a and b are in place and therefore the addition of the note to page 3/4 4-14 was incorrect and the note needed to be moved to TS page 3/4 4-14b. These changes are editorial-in-nature and the NRC staff concludes that it is acceptable. In addition in the July 1, 2008, letter, a typographical error on TS page 3/4 4-14, Item e of Limiting Condition for Operation 3.4.6.2 was corrected changing the reference from Table 3.4.6.1 to Table 3.4.6-1.

4.0 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.

5.0 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 previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published May 6, 2008 (73 FR 25039). 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.

6.0 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.

7.0 REFERENCES

1. WCAP-11618, "Criteria Application," with Addendum, November 21, 1989.

Principal Contributor: A. Wang Date: July 23, 2008