ML112790381

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Summary of Meeting with Entergy Operations, Inc. to Discuss Amendment Request to Revise Arkansas Nuclear One, Unit 2's Fuel Handling Accident (FHA) Analysis and Several TSTFs 51, 272, 286, and 471 That Support FHA
ML112790381
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 11/01/2011
From: Kalyanam N
Plant Licensing Branch IV
To:
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC ME6887
Download: ML112790381 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 1, 2011 LICENSEE: Entergy Operations, Inc.

FACILITY: Arkansas Nuclear One, Unit 2

SUBJECT:

SUMMARY

OF OCTOBER 5,2011, MEETING WITH ENTERGY OPERATIONS, INC., ON PRE-SUBMITTAL LICENSE AMENDMENT REQUEST FOR CHANGES DUE TO REVISED FUEL HANDLING ACCIDENT ANALYSIS ALONG WITH ADOPTION OF TSTF-51, TSTF-272, TSTF-286, TSTF-471, AND RELOCATION/DELETION OF NON-IMPROVED TECHNICAL SPECIFICATION (ITS) SHUTDOWN TECHNICAL SPECIFICATIONS (TAC NO. ME6887)

On October 5, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Entergy Operations, Inc. (Entergy, the licensee), for Arkansas Nuclear One, Unit 2 (ANO-2) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The meeting notice and agenda, dated August 31,2011, is available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML112350675. The licensee's slide presentation is available at ADAMS Accession No. ML112650269.

Entergy stated that due to the time involved and cost of making changes to Technical Specifications (TSs), it reviewed a number of anticipated changes being considered and determined that the four Technical Specification Task Force (TSTF) change travelers, namely, TSTF-51, TSTF-272, TSTF-286, and TSTF-471 1, should be submitted simultaneously with the TS changes that support its new fuel handling accident (FHA) analysis. This part of the change is related to the Alternate Source Term recently approved for ANO-22. The licensee stated that the request is intended to address non-conservative TSs. Entergy also stated that these non-conservative TSs are being tracked by a Condition Report and administrative controls are already in place in accordance with NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," dated December 29, 1998 (ADAMS Accession No. ML031110108). Finally, Entergy indicated it plans to relocate certain TSs to the Technical Requirements Manual and delete certain shutdown TSs not in the Improved Technical Specification (ITS) Shutdown. Entergy expects to submit the application for the license amendment request in December 2011 or January 2012.

TSTF-51, "Revise Containment Requirements during Handling Irradiated Fuel and Core Alterations";

TSTF-272, Revision 1, "Refueling Boron Concentration Clarification": TSTF-286, Revision 2, "Operations Involving Positive Reactivity Additions"; and TSTF-471, Revision 1, "Eliminate Use of Term Core Alterations in Actions and Notes."

2 Kalyanam, N. K., U.S. Nuclear Regulatory Commission, "Arkansas Nuclear One, Units No.2 Issuance of Amendment Re: Use of Alternate Source Term (TAC No. ME3678)," dated April 26, 2011 (ADAMS Accession No. ML110980197), as corrected by letter dated August 9, 2011 (ADAMS Accession No. ML111511001).

-2 Questions and comments from the NRC staff included:

  • The NRC staff questioned whether the licensee should change the wording of the revised TS 3.7.6.1 (and elsewhere), " ... during movement of irradiated fuel assemblies or movement of any fuel assembly over irradiated fuel assemblies,"

to cover other possible loads (such as dummies) to avoid confusion with what is covered and what is not.

  • The NRC staff questioned the clarity of the amendment request description for TS 3.4.1.3 that Mode 6 is captured elsewhere and provide other missing links.
  • Requested the review of the verification times in Surveillance Requirements (SR) in the deleted SR 4.1.1.3 and the new SR 4.1.1.3.4.
  • The NRC staff noted challenges in bundling TSTFs whereby an inadequacy in the submittal of one TSTF could hold back the approval of other TSTFs or cause undue complexity in generating a "No Significant Hazards Consideration" pursuant to paragraph 50.91 of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.
  • ANO-2 is a non-ITS plant. As such, changes, such as TSTF as well as the non TSTF-related changes, must be justified on their own merits. A reason such as a specific ANO-2 TS requirement does not exist in the ITS, may not provide a valid justification for deleting/relocating that requirement.

No members of the public were in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to Kaly N. Kalyanam at 301-415-1480 or kaly.kalyanam@nrc.gov.

N. Kalyanam, Project Manager Plant licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

list of Attendees cc w/encl: Distribution via listserv

LIST OF ATTENDEES PRE-SUBMITTAL MEETING WITH ENTERGY OPERATIONS, INC.

OCTOBER 5, 2011 TECHNICAL SPECIFICATION (TS) CHANGES DUE TO REVISED FUEL HANDLING ACCIDENT ANALYSIS AND ADOPTION OF TSTF-51, TSTF-272, TSTF-286, TSTF-471, AND RELOCATIONIDELETION OF NON-IMPROVED TS SHUTDOWN TS (TAC NO. ME6887)

ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-368 Nuclear Regulatory Commission G. Casto, NRRIDSS/SBPB K. Wood, NRR/DSS/SRXB R. Grover, NRR/DSS/STSB D. Duvigneaud, NRR/DRAlAADB N. Kalyanam, NRR/DORLlLPL4 Entergy Operations, Inc.

Dale James David Bice Enclosure

-2 Questions and comments from the NRC staff Included

  • The NRC staff questioned whether the licensee should change the wording of the revised TS 3.7.6.1 (and elsewhere), " .. during movement of irradiated fuel assemblies or movement of any fuel assembly over irradiated fuel assemblies,"

to cover other possible loads (such as dummies) to avoid confusion with what is covered and what is not.

  • The NRC staff questioned the clarity of the amendment request description for TS 3.4.1.3 that Mode 6 is captured elsewhere and provide other missing links.
  • Requested the review of the verification times in Surveillance Requirements (SR) in the deleted SR 4.1.1.3 and the new SR 4.1.1.3.4.
  • The NRC staff noted challenges in bundling TSTFs whereby an inadequacy in the submittal of one TSTF could hold back the approval of other TSTFs or cause undue complexity in generating a "No Significant Hazards Consideration" pursuant to paragraph 50.91 of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.
  • ANO-2 is a non-ITS plant. As such, changes, such as TSTF as well as the non TSTF-related changes, must be justified on their own merits. A reason such as a specific ANO-2 TS requirement does not exist in the ITS, may not provide a valid justification for deleting/relocating that requirement.

No members of the public were in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to Kaly N. Kalyanam at 301-415-1480 or kaly.kalyanam@nrc.gov.

/RA/

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

Enclosure:

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