ML102640229

Nonacceptance with Opportunity to Supplement Email, License Amendment Request to Revise TS 3.7.3, Mfivs, Main Feedwater Block Valves, Low Load Feedwater Control Valves and Startup Feedwater Control Valves

ML102640229
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/20/2010
From:	Kalyanam N Plant Licensing Branch IV
To:	David Bice, Clark R Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC ME4564
Download: ML102640229 (1)

Text

From: Kalyanam, Kaly Sent: Monday, September 20, 2010 4:21 PM To: BICE, DAVID B; CLARK, ROBERT W Cc: Burkhardt, Janet; Lent, Susan; Lingam, Siva; Boyle, Patrick

Subject:

Acceptance Review Result - LAR TAC No. ME4564

SUBJECT:

Acceptance Review Report -Arkansas Nuclear One-Unit 1, License Amendment Request dated August 24, 2010.

Request for Supplemental Information to start the Acceptance Review (TAC No.

ME4564)

TO: Dave Bice/Robert Clark DOCKET No.: 50-313 Date; September 20, 2010 By letter dated August 24, 2010, Entergy Operations Inc. (Entergy, the licensee),

submitted an License Amendment Request for the Arkansas Nuclear One, Unit 1 (ANO-1). The proposed change revises the Technical Specification (TS) 3.7.3 MFIVs, Main Feedwater Block Valves, Low Load Feedwater Control Valves and Startup Feedwater Control Valves and its associated Bases to permit manual operation of main feedwater valves provided the associated flow path remains automatically isolable via an operable MFW valve.

Entergy states in its application that Action E.1 under TS 3.7.1 is required when any two valves in a given flow path are inoperable. This includes valves parallel to one another, even if the flow path can still be isolated automatically by an operable valve. The purpose of requiring entry into Action E.1 is to ensure sufficient remedial action is initiated in the event a common mode failure exists. The proposed change will add an exception to this requirement for conditions when common mode failure is known not to exist, such as during plant startup when parallel valves may be operated in manual from the control room.

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 technical specifications) must fully describe the changes requested, and following 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 first 2 items stated below were discussed with your staff, Dave Bice and Robert Clark, on September 20, 2010.

In order to make the application complete, the NRC staff requests that Entergy supplement the application to address the information requested below by October 20, 2010. This will enable the NRC staff to begin its detailed technical review. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staffs detailed technical review by separate correspondence. Please let us know if you are unable to meet this date.

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

Kaly N. Kalyanam Project Manager, ANO-1 and 2 and Waterford 3 NRR/DORL/LPL4 SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE REVIEW TO COMMENDCE The existing TS 3.7.3 Condition E is specific and directs the operators to enter an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion time to isolate the affected flow path if two valves in the same flow path are inoperable for one or more flow paths.

1. In the amendment, the licensee is proposes to add a note to Technical Specification (TS) 3.7.3 Condition E. to state Not applicable to valves in parallel except where a common mode failure exists. The staff finds the note unacceptable. TS conditions are supposed to define a plant condition and provide a required action within a certain completion time. The note the licensee is adding does not define a plant condition and it actually makes the existing condition vague.

With the qualifying statement the licensee proposes to add, the plant operators will not be able to determine the status of the plant (flow paths) when the valves are declared inoperable. One scenario is, when a detailed root cause evaluation is done to determine the cause(s) of the failure of the two valves, it may lead to a scenario where a common cause failure mode exists.

Thus, the proposed TS revision does not define a plant condition for the operators to take appropriate action to guarantee the safety function. Please provide additional information as required.

2. The revision proposed by the licensee does not define a specific plant condition for the plant equipment. The revision may not require the operator to enter the TS LCO for a broad spectrum of possible failure modes that originally caused these two valves to be inoperable. The licensee has not provided an evaluation of every possible failure mode, outside a common mode failure, that would exclude the operators from having to enter this LCO. Typically, TS Conditions define a specific condition or alignment of the plant equipment, in a specific reactor mode, that enables the operators to take appropriate actions.

3. Please explain how the Safety analysis used as the basis for your TS 3.7.3 remains valid should you change the TS as requested in your LAR.