ML14209A627

Request for Additional Information, Requests to Adopt Technical Specifications Task Force (TSTF)-431, Revision 3, for Unit 1 and TSTF-422, Revision 2 for Unit 2, Change in Technical Specifications End States.

ML14209A627
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/04/2014
From:	Peter Bamford Plant Licensing Branch IV
To:	Entergy Operations
Bamford P
References
TAC MF1182, TAC MF1199
Download: ML14209A627 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 4, 2014 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUESTS TO ADOPT CHANGES TO TECHNICAL SPECIFICATION END STATES (TAC NOS. MF1182 AND MF1199)

Dear Sir or Madam:

By two letters dated March 26, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML13085A282 and ML13085A283), Entergy Operations, Inc.

(Entergy, the licensee), submitted license amendment requests (LARs) proposing changes to the Technical Specifications (TS) for Arkansas Nuclear One, Units 1 and 2. The proposed amendments would modify the TS requirements for end states associated with the implementation of Technical Specification Task Force (TSTF) traveler TSTF-431, "Change in Technical Specifications End States (BAW-2441 )," for Unit 1, and TSTF-422, Revision 2, "Change in Technical Specifications End States (CE NPSD-1186)," for Unit 2. Both TSTFs may be found at ADAMS Accession No. ML093570241. The proposed end states modifications would permit, for some systems, entry into a hot shutdown (Mode 4) end state rather than the current cold shutdown (Mode 5) end state. Supplements to the LARs were submitted by Entergy on November 14, 2013 (ADAMS Accession No. ML13319A877 for Unit 1), and December 12, 2013 (ADAMS Accession No. ML13347B235 for Unit 2).

The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review. The specific question is found in the enclosed request for additional information (RAI). The question was sent via electronic transmission on July 28, 2014, to Mr. David Bice, of your staff. The draft question was sent to ensure that it was understandable, the regulatory basis was clear, and to determine if the information was previously docketed. After reviewing the draft question, Mr. Bice indicated that there was no need for a clarification teleconference regarding the RAI. The NRC staff requests that you respond within 30 days of the date of this letter.

If you have any questions regarding this matter, I may be reached at 301-415-2833.

Sincerely,

~

Peter J. Bamford, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUESTS PROPOSING ADOPTION OF TSTF-431, REVISION 3 (UNIT 1) AND TSTF-422, REVISION 2 (UNIT 2)

REGARDING TECHNICAL SPECIFICATION END STATES ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 DOCKET NOS. 50-313 AND 50-368 By two letters dated March 26, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML13085A282 and ML13085A283), Entergy Operations, Inc.

(Entergy, the licensee), submitted license amendment requests (LARs) proposing changes to the Technical Specifications (TS) for Arkansas Nuclear One (ANO), Units 1 and 2. The proposed amendments would modify the TS requirements for end states associated with the implementation of Technical Specification Task Force (TSTF) traveler TSTF-431, "Change in Technical Specifications End States (BAW-2441)," for Unit 1, and TSTF-422, Revision 2, "Change in Technical Specifications End States (CE NPSD-1186)," for Unit 2. Both TSTFs may be found at ADAMS Accession No. ML093570241. The proposed end states modifications would permit, for some systems, entry into a hot shutdown (Mode 4) end state rather than the current cold shutdown (Mode 5) end state. Supplements to the LARs were submitted by Entergy on November 14, 2013 (ADAMS Accession No. ML13319A877 for Unit 1), and December 12, 2013 (ADAMS Accession No. ML13347B235 for Unit 2). In order for the U.S. Nuclear Regulatory Commission (NRC) staff to complete its review of the LARs, a response to the following request for additional information is requested.

Background:

During the LAR review, the NRC staff noticed that one of the regulatory guidance documents used in the staff's regulatory assessment for the TSTFs, and referenced in the staff's associated model safety evaluations, has since been superseded and therefore, is not valid guidance for the adoption of approved TSTF. The issue concerns a specific reference to Regulatory Guide (RG) 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," contained in both TSTF-431 and TSTF-422.

RG 1.182 was withdrawn since it was determined that the document was redundant due to the inclusion of its subject matter in Revision 3 of RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated May 2012 (ADAMS Accession No. ML113610098). The withdrawal notice for RG 1.182 was published in the Federal Register on November 27,2012 (78 FR 70846). The notice also states that withdrawal of RG 1.182 neither altered any prior or existing licensing commitments based on its use, nor constituted backfitting as defined in Title 10 of the Code of Federal Regulations (1 0 CFR), Section 50.109 (the Backfit Rule), and was not otherwise inconsistent with the issue finality provisions in 10 CFR Part 52.

Enclosure

In addition, the NRC staff observed that RG 1.160 endorsed Revision 4A of the Nuclear Management and Resources Council (NUMARC) 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated April 2011 (ADAMS Accession No. ML11116A198). NUMARC 93-01 provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The model safety evaluation for the TSTFs currently refers to the guidance in Revision 2 of the NUMARC 93-01, dated April 1996 (ADAMS Accession No. ML101020415).

Request for Additional Information:

In order to justify adoption of the TSTF changes, please confirm that ANO, Units 1 and 2, adhere to the RG 1.160 guidance, including the updated version of NUMARC 93-01. In addition, please confirm that the topical reports supporting the LARs comply with NUMARC 93-01, Section 11, and identify, if any, inconsistencies with this section.

ML14209A627 OFFICE NRRJDORL/LPL4-1/PM NRRJDORLILPL4-1/LA NRR/DSS/STSB/BC NRRJDORL/LPL4-1/BC NRRJDORLILPL4-1 /PM NAME PBamford JBurkhardt REIIiott EOesterle PBamford DATE 7/29/14 7/29/14 7/29/14 8/1/14 8/4/14