ML092290315

Supplemental Information Needed Prior to Acceptance, License Amendment Request to Relocate Heater Requirements Portion of Technical Specification 3.4.4, Pressurizer, to the Technical Requirements Manual

ML092290315
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/17/2009
From:	Kalyanam N Plant Licensing Branch IV
To:	David Bice, Clark R Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC ME1622
Download: ML092290315 (3)

Text

From: Kalyanam, Kaly Sent: Monday, August 17, 2009 10:27 AM To: BICE, DAVID B; CLARK, ROBERT W Cc: Burkhardt, Janet; Lent, Susan; Feintuch, Karl; Lingam, Siva

Subject:

Acceptance Review of ANO-2 LAR, Technical Specification Changes To Relocate Pressurizer Heater By letter dated June 18, 2009, Entergy Operations, Inc., submitted a license amendment request for Arkansas Nuclear One, Unit 2. The proposed change will relocate portions of Technical Specification (TS) 3.4.4, Pressurizer, to the Technical Requirements Manual (TRM).

TS 3.4.4 specifies operability requirements for both the water volume in the Pressurizer and the electric heater capacity of the Pressurizer. The proposed change will relocate the heater requirements to the TRM.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the TS) must fully describe the changes requested, and follow as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.

The NRC staff has reviewed your application and concluded that it does not provide technical information in sufficient detail to enable the staff to proceed with its detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment. Specifically, in the probabilistic risk assessment area, other than a single sentence that simply repeats the regulatory requirement, the current application does not explain the basis (criterion used) for determining that the plant-specific PRA does not show the pressurizer heaters are risk significant. Thus, the LAR does not adequately address this area.

Secondly, the staff position on compliance with 10 CFR 50.36(c)(2)(ii) considers that the heaters are (a) design feature of the pressurizer, (b) required to be operable to satisfy Criterion 2, and (c) though the heaters are not specifically used in accident analysis, yet as indicated in NUREG-0737, the heaters are powered from emergency power supply and are needed to maintain subcooling in the long term during loss of offsite power, therefore, it appeared that the LCO and Action b for the pressurizer heaters must remain with in the TS. If additional information is needed for the staff to complete its technical review, you will be advised by separate correspondence.

In order to make the application complete, the NRC staff requests that Entergy supplement the application to address the information requested above by September 8, 2009. This will enable the NRC staff to complete its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC staff will cease its review activities associated with the

application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.

If you have any questions, please contact me, at (301) 415-1480.

N. Kalyanam Project Manager E-mail Properties Mail Envelope Properties (CEEA97CC21430049B821E684512F6E5ECA56255C3F)

Subject:

Acceptance Review of ANO-2 LAR, Technical Specification Changes To Relocate Pressurizer Heater Sent Date: 8/17/2009 10:27:27 AM Received Date: 8/17/2009 10:27:27 AM From: Kalyanam, Kaly Created By: Kaly.Kalyanam@nrc.gov Recipients:

DBICE@entergy.com (BICE, DAVID B)

Tracking Status: None RCLARK@entergy.com (CLARK, ROBERT W)

Tracking Status: None Janet.Burkhardt@nrc.gov (Burkhardt, Janet)

Tracking Status: None Susan.Lent@nrc.gov (Lent, Susan)

Tracking Status: None Karl.Feintuch@nrc.gov (Feintuch, Karl)

Tracking Status: None Siva.Lingam@nrc.gov (Lingam, Siva)

Tracking Status: None Post Office:

HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 12163 8/17/2009 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False

Sensitivity: olNormal Recipients received: