2CAN041904, Response to Request for Additional Information Related to the Application to Technical Specification Actions to Address Inoperability of the Containment Building Sump
| ML19120A084 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/30/2019 |
| From: | Gaston R Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN041904 | |
| Download: ML19120A084 (15) | |
Text
10 CFR 50.90 2CAN041904 April 30, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Response to Request for Additional Information Related to the Application to Technical Specification Actions to Address Inoperability of the Containment Building Sump Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6
REFERENCES:
- 1.
Entergy Operations, Inc. letter to U. S. Nuclear Regulatory Commission, License Amendment Request to Add Actions to Address Inoperability of the Containment Building Sump, Arkansas Nuclear One, Unit 2 (2CAN121801) (ML18353B049), dated December 19, 2018
- 2.
U. S. Nuclear Regulatory Commission email to Entergy Operations, Inc.,
Request for Additional Information Regarding License Amendment Request to Add Technical Specification Actions to Address Inoperability of the Containment Building Sump (EPID L-2018-LLA-0573)
(2CNA041902) (ML19106A432), dated April 16, 2019 By letter dated December 19, 2018 (Reference 1), Entergy Operations, Inc. (Entergy),
requested NRC approval of a proposed change to the Arkansas Nuclear One, Unit 2 (ANO-2)
Technical Specifications (TSs). The proposed amendment would establish Actions and Allowable Outage Times (AOTs) applicable to conditions where the ANO-2 containment building sump is inoperable.
By email dated April 15, 2019, the NRC informed Entergy that additional information is needed to support the Staffs continued review of the application. A clarification call between the NRC and the licensee was held on April 16, 2019. The final request for additional information (RAI) was received via email on April 16, 2019 (Reference 2) with a response required within 30 days. The enclosure includes a summary of the Request for Additional Information (RAI) and Entergys Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing
2CAN041904 Page 2 of 2 response. The response includes a change to both the markup and re-typed pages for the proposed containment building sump TS, along with the associated affected TS Bases pages.
These pages are provided in Attachments 1, 2, and 3 of the enclosure. Entergy's response to this RAI does not impact the No Significant Hazards Consideration of the Reference 1 letter.
No new regulatory commitments are included in this amendment request.
In accordance with 10 CFR 50.91, Entergy is notifying the State of Arkansas of Entergy's response to this RAI by transmitting a copy of this letter and enclosure to the designated State Official.
If there are any questions or if additional information is needed, please contact Tim Arnold at 479-858-7826.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 30, 2019.
Sincerely, ORIGINAL SIGNED BY RON GASTON Ron Gaston RG/dbb
Enclosure:
Response to Request for Additional Information Attachments to
Enclosure:
- 1.
Technical Specification Page Markups
- 2.
Re-typed Technical Specification Pages
- 3.
Technical Specification Bases Page Markups (For Information Only) cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205
Enclosure to 2CAN041904 Response to Request for Additional Information
Enclosure to 2CAN041904 Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated December 19, 2018 (Reference 1), Entergy Operations, Inc. (Entergy),
requested NRC approval of a proposed change to the Arkansas Nuclear One, Unit 2 (ANO-2)
Technical Specifications (TSs). The proposed amendment would establish Actions and Allowable Outage Times (AOTs) applicable to conditions where the ANO-2 containment building sump is inoperable.
By email dated April 16, 2019 (Reference 2), the NRC informed Entergy that additional information is needed to support the Staffs continued review of the application. A clarification call between the NRC and the licensee was held on April 16, 2019. The specific questions presented in the Reference 2 Request for Addition Information (RAI) are repeated below for ease of review. Entergys response is provided thereafter.
RAI-1
The licensees proposed new TS 3.6.4.1, ACTION "a" states, in part:
With the containment sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits, LCO 3.5.2, "ECCS Subsystems -Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems - Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System, may be considered met [emphasis added] provided: []"
For clarity of the TSs, consider revising new proposed ACTION "a" with respect to (non) entry into the ACTIONs of LCOs 3.5.2, 3.5.3, and 3.6.2.1, in lieu of meeting the respective LCOs, as currently proposed.
Entergy Response As stated in Entergy's December 19, 2018 (Reference 1) letter, the intent of the proposed addition of a new Containment Sump TS was, in part, to gain or maintain consistency with NUREG 1432, "Standard Technical Specifications for Combustion Engineering Plants" (STS). The proposed change described in the above RAI description was intended to be consistent with STS Limiting Condition for Operation (LCO) 3.0.6, which permits avoiding entry into applicable Conditions and Required Actions of TS supported system LCOs while complying with the Conditions and Required Actions of a TS support system LCO. However, the above wording does not clearly capture this intent. Therefore, in response to the NRC's request and to gain improved consistency with the STS, Entergy is revising the above ACTION "a" wording as follows (emphasis added):
With the containment sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits, entry into the applicable ACTION(s) of LCO 3.5.2, "ECCS Subsystems -Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems -
Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System," is not required provided:
As a result of this wording revision, the markup of the respective TS Bases ACTION "a" is also revised to ensure proper application of the requirements by Operations personnel. The TS Bases changes are derived, in part, from the STS Bases associated with LCO 3.0.6.
Enclosure to 2CAN041904 Page 2 of 3
RAI-2
The licensees proposed new TS 3.6.4.1, Action "a.3" states:
- 3.
The containment sump to restored to OPERABLE status within 90 days.
The proposed sentence appears to be missing a word or words. Please modify proposed ACTION "a.3" to enhance the clarity of the TSs.
Entergy Response The ACTION "a.3" wording is revised by replacing the first use of the word "to" with "is":
- 3.
The containment sump is restored to OPERABLE status within 90 days.
In addition to the above, minor wording additions have been made to proposed new TS 3.6.4.1 for better consistency with other ANO-2 TSs. ACTIONs b.1 and b.2 are revised as follows (emphasis added):
[b]1. Immediately enter the applicable ACTIONS of LCO 3.5.2, ECCS Subsystems -
Tavg 300 °F and LCO 3.5.3, ECCS Subsystems - Tavg < 300 °F, for emergency core cooling trains made inoperable by the containment sump, and
[b]2. Immediately enter the applicable ACTIONS of LCO 3.6.2.1, Containment Spray System, for containment spray trains made inoperable by the containment sump, and Surveillance Requirement (SR) 4.6.4.1.1 is revised as follows (emphasis added):
At least once per 18 months verify, by visual inspection, that the containment sump does not show structural damage, abnormal corrosion, or debris blockage.
These changes are editorial in nature and do not change the meaning or intent of any ACTION or SR.
Entergy's December 19, 2018, amendment request (Reference 1) noted that the TS markup and retyped pages included in the submittal would be affected (changed) by Entergy's proposal to adopt TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5 (Reference 3). TSTF-425 revises TS 4.5.2.d from an 18-month frequency to "in accordance with the Surveillance Frequency Control Program." The NRC approved TSTF-425 in Amendment 315 to the ANO-2 TS on April 23, 2019 (Reference 4). Therefore, SR 4.6.4.1.1 of the proposed new Containment Sump TS is revised to include the application of the Surveillance Frequency Control Program consistent with the changes to TS SR 4.5.2.d by TSTF-425, as approved in ANO-2 TS Amendment 315. In addition, the markup and retyped TS 3.5.2 page (Page 3/4 5-4) included in the Reference 1 amendment request is revised in accordance with ANO-2 TS Amendment 315 and provided as part of the response to this RAI.
Enclosure to 2CAN041904 Page 3 of 3 Entergy has included revised markup and retyped TS pages in Attachments 1 and 2 of this enclosure which incorporate the above changes. A revised markup to the affect TS Bases (Pages B 3/4 6-12 and B 3/4 6-13) associated with the new Containment Sump TS is also provided in Attachment 3, for information only. Entergy believes the foregoing responses are consistent with the discussions held between the NRC and the licensee on April 16, 2019, and consistent with the changes incorporated via ANO-2 TS Amendment 315.
6.0 REFERENCES
- 1.
Entergy Operations, Inc. letter to U. S. Nuclear Regulatory Commission, License Amendment Request to Add Actions to Address Inoperability of the Containment Building Sump, Arkansas Nuclear One, Unit 2, dated December 19, 2018 (2CAN121801) (ML18353B049)
- 2.
U. S. Nuclear Regulatory Commission email to Entergy Operations, Inc., Request for Additional Information Regarding License Amendment Request to Add Technical Specification Actions to Address Inoperability of the Containment Building Sump, dated April 16, 2019 (EPID L-2018-LLA-0573) (2CNA041902) (ML19106A432)
- 3.
Entergy Operations, Inc. letter to U. S. Nuclear Regulatory Commission, Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425), Arkansas Nuclear One, Unit 2, dated February 6, 2018 (2CAN021802)
- 4.
U. S. Nuclear Regulatory Commission letter to Entergy Operations, Inc., Arkansas Nuclear One, Unit 2 - Issuance of Amendment Re: Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-425, Revision 3, dated April 23, 2019 (EPID L-2018-LLA-0047) (2CNA041904) (ML19063B948)
ATTACHMENTS
- 1.
Technical Specification Page Markups
- 2.
Retyped Technical Specification Pages
- 3.
Technical Specification Bases Page Markups (For Information Only)
Enclosure Attachment 1 to 2CAN041904 Technical Specification Page Markups (2 pages)
ARKANSAS - UNIT 2 3/4 5-4 Amendment No. 39,162,251,258,
- 315, EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:
- a.
In accordance with the Surveillance Frequency Control Program by verifying that the following valves are in the indicated positions with power to the 2CV-5101-1 and 2CV-5102-2 valve operators removed:
Valve Number Valve Function Valve Position 2CV-5101-1 HPSI Hot Leg Injection Isolation Closed 2CV-5102-2 HPSI Hot Leg Injection Isolation Closed 2BS-26 RWT Return Line Open
- b.
In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.
- c.
By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.)
is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:DELETED
- 1.
For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and
- 2.
At least once daily of the areas affected within containment if containment has been entered that day, and during the final entry when CONTAINMENT INTEGRITY is established.
- d.
In accordance with the Surveillance Frequency Control Program by a visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.DELETED
- e.
In accordance with the Surveillance Frequency Control Program, during shutdown, by:
- 1.
Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and RAS test signals.
- 2.
Verifying that each of the following pumps start automatically upon receipt of a Safety Injection Actuation Test Signal:
- a.
High-Pressure Safety Injection pump.
- b.
Low-Pressure Safety Injection pump.
ARKANSAS - UNIT 2 3/4 6-18 Amendment No.
CONTAINMENT SYSTEMS CONTAINMENT SUMP LIMITING CONDITION FOR OPERATION 3.6.4.1 The containment sump shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3 and 4.
ACTION:
- a.
With the containment sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits, entry into the applicable ACTION(s) of LCO 3.5.2, "ECCS Subsystems - Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems -
Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System," is not required provided:
- 1.
Action is initiated immediately to mitigate containment accident generated and transported debris, and
- 2.
SR 4.4.6.2.1.a is performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
- 3.
The containment sump is restored to OPERABLE status within 90 days.
- b.
With the containment sump inoperable for reasons other than ACTION a:
- 1.
Immediately enter the applicable ACTIONS of LCO 3.5.2, "ECCS Subsystems -
Tavg 300 °F" and LCO 3.5.3, "ECCS Subsystems - Tavg < 300 °F," for emergency core cooling trains made inoperable by the containment sump, and
- 2.
Immediately enter the applicable ACTIONS of LCO 3.6.2.1, "Containment Spray System," for containment spray trains made inoperable by the containment sump, and
- 3.
Restore the containment sump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REQUIREMENTS 4.6.4.1.1 Verify, by visual inspection, that the containment sump does not show structural damage, abnormal corrosion, or debris blockage in accordance with the Surveillance Frequency Control Program.
Enclosure Attachment 2 to 2CAN041904 ReTyped Technical Specification Pages (2 pages)
ARKANSAS - UNIT 2 3/4 5-4 Amendment No. 39,162,251,258,
- 315, EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:
- a.
In accordance with the Surveillance Frequency Control Program by verifying that the following valves are in the indicated positions with power to the 2CV-5101-1 and 2CV-5102-2 valve operators removed:
Valve Number Valve Function Valve Position 2CV-5101-1 HPSI Hot Leg Injection Isolation Closed 2CV-5102-2 HPSI Hot Leg Injection Isolation Closed 2BS-26 RWT Return Line Open
- b.
In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.
- c.
DELETED
- d.
DELETED
- e.
In accordance with the Surveillance Frequency Control Program, during shutdown, by:
- 1.
Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and RAS test signals.
- 2.
Verifying that each of the following pumps start automatically upon receipt of a Safety Injection Actuation Test Signal:
- a.
High-Pressure Safety Injection pump.
- b.
Low-Pressure Safety Injection pump.
ARKANSAS - UNIT 2 3/4 6-18 Amendment No.
CONTAINMENT SYSTEMS CONTAINMENT SUMP LIMITING CONDITION FOR OPERATION 3.6.4.1 The containment sump shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3 and 4.
ACTION:
- a.
With the containment sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits, entry into the applicable ACTION(s) of LCO 3.5.2, "ECCS Subsystems - Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems -
Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System," is not required provided:
- 1.
Action is initiated immediately to mitigate containment accident generated and transported debris, and
- 2.
SR 4.4.6.2.1.a is performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
- 3.
The containment sump is restored to OPERABLE status within 90 days.
- b.
With the containment sump inoperable for reasons other than ACTION a:
- 1.
Immediately enter the applicable ACTIONS of LCO 3.5.2, ECCS Subsystems -
Tavg 300 °F and LCO 3.5.3, ECCS Subsystems - Tavg < 300 °F, for emergency core cooling trains made inoperable by the containment sump, and
- 2.
Immediately enter the applicable ACTIONS of LCO 3.6.2.1, Containment Spray System, for containment spray trains made inoperable by the containment sump, and
- 3.
Restore the containment sump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REQUIREMENTS 4.6.4.1.1 Verify, by visual inspection, that the containment sump does not show structural damage, abnormal corrosion, or debris blockage in accordance with the Surveillance Frequency Control Program.
Enclosure Attachment 3 to 2CAN041904 Technical Specification Bases Page Markups - Information Only (2 pages)
ARKANSAS - UNIT 2 B 3/4 6-12 Rev.
CONTAINMENT SYSTEMS BASES 3/4.6.4.1 CONTAINMENT SUMP (continued)
ACTIONS a.1, a.2, and a.3 ACTION a is applicable when there is a condition which results in containment accident generated and transported debris exceeding the analyzed limits. Containment debris limits are defined in engineering calculations. The ACTION states that entry into the applicable ACTION(s) of LCO 3.5.2, "ECCS Subsystems - Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems
- Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System," is not required provided specific remedial actions are taken as described in ACTIONs a.1, a.2, and a.3. Therefore, while the aforementioned LCOs are not met, compliance with the ACTIONs of these LCOs is not required. This is an exception to LCO 3.0.2, which would require that the ACTIONS of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's ACTIONs.
When ACTION a is entered, immediate action must be initiated to mitigate the condition.
Examples of mitigating actions are:
Removing the debris source from containment or preventing the debris from being transported to the containment sump; Evaluating the debris source against the assumptions in the analysis; Deferring maintenance that would affect availability of the affected systems and other LOCA mitigating equipment; Deferring maintenance that would affect availability of primary defense-in-depth systems, such as containment coolers; Briefing operators on LOCA debris management actions; or Applying an alternative method to establish new limits.
While in this condition, the RCS water inventory balance, SR 4.4.6.2.1.a, must be performed at an increased Frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An unexpected increase in RCS leakage could be indicative of an increased potential for an RCS pipe break, which could result in debris being generated and transported to the containment sump. The more frequent monitoring allows operators to act in a timely fashion to minimize the potential for an RCS pipe break while the containment sump is inoperable.
The inoperable containment sump must be restored to OPERABLE status in 90 days. A 90-day allowable outage time (AOT) is reasonable for emergent conditions that involve debris in excess of the analyzed limits that could be generated and transported to the containment sump under accident conditions. The likelihood of an initiating event in the 90-day AOT is very small and there is margin in the associated analyses. The mitigating actions of ACTION a.1 provides additional assurance that the effects of debris in excess of the analyzed limits will be mitigated during the AOT.
ARKANSAS - UNIT 2 B 3/4 6-13 Rev.
CONTAINMENT SYSTEMS BASES 3/4.6.4.1 CONTAINMENT SUMP (continued)
ACTIONS (continued) b.1, b.2, and b.3 When the containment sump is inoperable for reasons other than ACTION a, such as blockage, structural damage, or abnormal corrosion that could prevent recirculation of coolant, it must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72-hour AOT takes into account the reasonable time for repairs, and low probability of an accident that requires the containment sump occurring during this period.
ACTION b.1 requires that the applicable ACTIONs of LCO 3.5.2, "ECCS Subsystems -
Tavg 300 °F," and LCO 3.5.3, "ECCS Subsystems - Tavg < 300 °F," be entered if an inoperable containment sump results in an inoperable ECCS train. In addition, ACTION b.2 requires that the applicable actions of LCO 3.6.2.1, "Containment Spray System," be entered if an inoperable containment sump results in an inoperable CSS train.
If the associated AOTs of ACTIONs a.1, a.2, a.3, b.1, b.2, and/or b.3 are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 (HOT STANDBY) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 (COLD SHUTDOWN) within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The AOTs are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE REQUIREMENTS SR 4.6.4.1.1 Periodic inspections are performed to verify the containment sump does not show current or potential debris blockage, structural damage, or abnormal corrosion to ensure the operability and structural integrity of the containment sump. The SR Frequency, controlled under the Surveillance Frequency Control Program, is based on the need to perform this SR during a refueling outage, because of the need to enter containment.