ML20034E874
| ML20034E874 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/16/2020 |
| From: | Thomas Wengert NRC/NRR/DORL/LPL4 |
| To: | Entergy Operations |
| Wengert T | |
| References | |
| EPID L-2019-LLA-0061 | |
| Download: ML20034E874 (25) | |
Text
March 16, 2020 ANO Site Vice President Arkansas Nuclear One Entergy Operations, Inc.
N-TSB-58 1448 S.R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNIT 1 - ISSUANCE OF AMENDMENT NO. 268 RE: ADOPTION OF TSTF-439, ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO (EPID L-2019-LLA-0061)
Dear Sir or Madam:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 268 to Renewed Facility Operating License No. DPR-51 for Arkansas Nuclear One, Unit 1 (ANO-1). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated March 25, 2019, as supplemented by letters dated October 23, 2019, and November 18, 2019.
The amendment revises the ANO-1 TSs to adopt Technical Specifications Task Force (TSTF)
Traveler TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [Limiting Condition for Operation], dated June 20, 2005.
Specifically, the amendment deletes second completion times from the affected required actions contained in the TSs, revises the example contained in TS Section 1.3, and adds a discussion about alternating between TS conditions.
A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.
Sincerely,
/RA G. Edward Miller for/
Thomas J. Wengert, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-313
Enclosures:
- 1. Amendment No. 268 to DPR-51
- 2. Safety Evaluation cc: Listserv
ENTERGY OPERATIONS, INC.
DOCKET NO. 50-313 ARKANSAS NUCLEAR ONE, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 268 Renewed License No. DPR-51
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Entergy Operations, Inc. (the licensee), dated March 25, 2019, as supplemented by letters dated October 23, 2019, and November 18, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.c.(2) of Renewed Facility Operating License No. DPR-51 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 268, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications.
- 3.
This amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License No. DPR-51 and Technical Specifications Date of Issuance: March 16, 2020
ATTACHMENT TO LICENSE AMENDMENT NO. 268 RENEWED FACILITY OPERATING LICENSE NO. DPR-51 ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313 Replace the following pages of the Renewed Facility Operating License No. DPR-51 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Operating License REMOVE INSERT 3
3 Technical Specifications REMOVE INSERT 1.3-3 1.3-3 1.3-5 1.3-5 1.3-6 1.3-6 3.6.5-1 3.6.5-1 3.7.5-1 3.7.5-1 3.8.1-2 3.8.1-2 3.8.1-3 3.8.1-3 3.8.7-1 3.8.7-1 3.8.9-1 3.8.9-1 (5)
EOI, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6)
EOI, pursuant to the Act and 1 O CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
- c.
This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
(2)
(3)
(4)
Maximum Power Level EOI is authorized to operate the facility at steady state reactor core power levels not in excess of 2568 megawatts thermal.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 268, are hereby incorporated in the renewed license.
EOI shall operate the facility in accordance with the Technical Specifications.
Safety Analysis Report The licensee's SAR supplement submitted pursuant to 10 CFR 54.21(d),
as revised on March 14, 2001, describes certain future inspection activities to be completed before the period of extended operation. The licensee shall complete these activities no later than May 20, 2014.
Physical Protection EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Arkansas Nuclear One Physical Security Plan, Training and Qualifications Plan, and Safeguards Contingency Plan," as submitted on May 4, 2006.
Renewed License No. DPR-51 Amendment No. 268 Revised by letter dated July 18, 2007
Completion Times 1.3 1.3 Completion Times (continued)
DESCRIPTION (continued)
EXAMPLES AN0-1 The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... "
The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.
Required B.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met.
B.2 Be in MODE 5.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition Bis entered.
The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
1.3-3 Amendment No. ~.~. 268
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
AN0-1 On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.
EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One A.1 Restore Function X 7 days Function X train to train OPERABLE inoperable.
status.
B.
One 8.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to train OPERABLE inoperable.
status.
C.
One C.1 Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function X train to train OPERABLE inoperable.
status.
AND OR One C.2 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to OPERABLE train status.
1.3-5 Amendment No. ~.~. 268
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
AN0-1 When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).
If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).
It is possible to alternate between Conditions A, 8, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Condition~ are not inappropriately extended.
1.3-6 Amendment No. ~.~. 268
Reactor Building Spray and Cooling System 3.6.5 3.6 REACTOR BUILDING SYSTEMS 3.6.5 Reactor Building Spray and Cooling Systems LCO 3.6.5 Two reactor building spray trains and two reactor building cooling trains shall be OPERABLE.
NOTE-------------------------------------
Only one train of reactor building spray and one train of reactor building cooling are required to be OPERABLE during MODES 3 and 4.
APPLICABILITY:
MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One reactor building spray A.1 Restore reactor building 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train inoperable in spray train to OPERABLE MODE 1 or 2.
status.
B.
One reactor building B.1 Restore reactor building 7days cooling train inoperable in cooling train to OPERABLE MODE 1 or 2.
status.
C.
Two reactor building C.1 Restore one reactor building 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> cooling trains inoperable cooling train to OPERABLE in MODE 1 or 2.
status.
AN0-1 3.6.5-1 Amendment No. 24-a, 268
- 3. 7 PLANT SYSTEMS 3.7.5 Emergency Feedwater (EFW) System LCO 3.7.5 Two EFW trains shall be OPERABLE.
EFWSystem 3.7.5
NOTE-----------------------------------
Only one EFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.
APPLICABILITY:
MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.
ACTIONS
NOTE-------------------------------------------------
LCO 3.0.4.b is not applicable when entering Mode 1.
CONDITION REQUIRED ACTION 1 COMPLETION TIME A.
Turbine driven EFW train A.1 Restore affected equipment 7days inoperable due to one to OPERABLE status.
inoperable steam supply.
NOTE------------
Only applicable if MODE 2 has not been entered following refueling.
Turbine driven EFW pump inoperable in MODE 3 following refueling.
B.
One EFW train inoperable B.1 Restore EFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in MODE 1, 2, or 3 for OPERABLE status.
reasons other than Condition A.
AN0-1 3.7.5-1 Amendment No.~.~.~. 268
CONDITION A.
(continued)
B.
One DG inoperable.
AN0-1 REQUIRED ACTION A.3
~-NOTE----------~--~-
Startup Transformer No. 2 may be removed from service for up to 30 days for preplanned preventative maintenance. This 30 day Completion Time may be applied not more than once in any 1 O year period.
Restore required offsite circuit to OPERABLE status.
B.1 Perform SR 3.8.1.1 for OPERABLE required offsite circuit(s).
AND B.2 Declare required feature(s) supported by the inoperable DG inoperable when its redundant required feature(s) is inoperable.
AND B.3.1 Determine OPERABLE DG is not inoperable due to common cause failure.
OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DG.
AND B.4 Restore DG to OPERABLE status.
AC Sources - Operating 3.8.1 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 1 hour AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours 7 days 3.8.1-2 Amendment No. 24-0,239, 268
CONDITION REQUIRED ACTION C.
Two required offsite C.1 Declare required feature(s) circuits inoperable.
inoperable when its redundant required feature(s) is inoperable.
AND C.2 Restore one required offsite circuit to OPERABLE status.
D.
One required offsite circuit
NOTE------------------
Enter applicable Conditions and Required Actions of LCO 3.8.6, AND "Distribution Systems - Operating,"
when Condition D is entered with One DG inoperable.
no AC power source to any train.
D.1 Restore required offsite circuit to OPERABLE status.
OR D.2 Restore DG to OPERABLE status.
E.
Two DGs inoperable.
E.1 Restore one DG to OPERABLE status.
AN0-1 3.8.1-3 AC Sources - Operating 3.8.1 COMPLETION TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery of Condition C concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 12 hours 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 hours Amendment No. 245-, 268
Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating LCO 3.8.7 APPLICABILITY:
ACTIONS The following inverters shall be OPERABLE.
- a.
Two Red Train inverters (Y11 and Y13, Y11 and Y15, or Y13 and Y15),
and
- b.
Two Green Train inverters (Y22 and Y24, Y22 and Y25, or Y24 and Y25),
NOTE-------------------------------------
One of the four inverters required by LCO 3.8.7.a and LCO 3.8.7.b may be disconnected from its associated DC bus for :::; 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform load transfer to or from the swing inverter, provided:
- a.
The associated 120 VAC bus is energized from its alternate AC source; and
- b.
The other three 120 VAC buses are energized from their associated OPERABLE inverters.
MODES 1, 2, 3, and 4.
CONDITION REQUIRED ACTION COMPLETION TIME A.
One of the four inverters required by LCO 3.8.7.a and LCO 3.8.7.b inoperable.
AN0-1 A.1
~------NOTE-------------
Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any of the 120 VAC buses RS1,RS2,RS3,orRS4 de-energized.
Restore inverter to OPERABLE status.
3.8.7-1 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Amendment No. 2-+a,230, 268
3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating Distribution Systems - Operating 3.8.9 LCO 3.8.9 Two AC, DC, and 120 VAC electrical power distribution subsystems shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One or more AC electrical A.1 Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution distribution subsystem(s) to subsystem(s) inoperable.
OPERABLE status.
B.
One or more 120 VAC B.1 Restore 120 VAC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> electrical power power distribution distribution subsystem(s) subsystem(s) to OPERABLE (RS1, RS2, RS3, RS4) status.
C.
One or more DC electrical C.1 Restore DC electrical power power distribution distribution subsystem(s) to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> subsystem(s) inoperable.
OPERABLE status.
D.
Required Action and D.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
AND D.2
NOTE--------------
LCO 3.0.4.a is not applicable when entering Mode 4.
Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AN0-1 3.8.9-1 Amendment No. ~.~.~.~. 268
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 268 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-51 ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313
1.0 INTRODUCTION
By application dated March 25, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19084A217), as supplemented by letters dated October 23, 2019, and November 18, 2019 (ADAMS Accession Nos. ML19296E587 and ML19322C319, respectively), Entergy Operations, Inc. (Entergy, the licensee) requested changes to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit 1 (ANO-1).
The amendment would revise the ANO-1 TSs to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [Limiting Condition for Operation], dated June 20, 2005 (ADAMS Accession No. ML051860296). The U.S. Nuclear Regulatory Commission (NRC or the Commission) approved the traveler on January 11, 2006 (ADAMS Accession No. ML060120272). Specifically, the amendment would delete second completion times (CTs) from the affected required actions contained in the TSs, revise the example contained in TS Section 1.3, and add a discussion about alternating between TS conditions in TS Section 1.3.
The licensees supplemental letter dated October 23, 2019, provided new markup and revised (clean) TS pages for those pages that were affected by the NRC staffs previous issuance of ANO-1 Amendment No. 265 dated September 11, 2019 (ADAMS Accession No. ML19175A042). The licensees letter dated November 18, 2019, stated its prior reference to Regulatory Guide (RG) 1.182, Assessing and Managing Risk before Maintenance Activities at Nuclear Power Plants, in its original application should have been RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3, dated May 2012 (ADAMS Accession No. ML113610098).
The supplemental letters dated October 23, 2019, and November 18, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register (FR) on June 4, 2019 (84 FR 25836).
2.0 REGULATORY EVALUATION
2.1
System Description
2.1.1 Completion Times The CT is the amount of time allowed for completing a required action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an action condition unless otherwise specified, provided the unit is in a mode or specified condition stated in the applicability of the LCO. Required actions must be completed prior to the expiration of the specified CT. An action condition remains in effect, and the required actions apply until the condition no longer exists or the unit is not within the LCO applicability.
The description section of the licensees TS 1.3, Completion Times, states, in part, that:
Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
Additional secondary CTs, such as limits on the period of time from discovery of the failure to meet the LCOs discussed above, were specified to prevent repeated entry and exit from alternating TS required actions.
2.1.2 Reactor Building Spray and Cooling Systems The reactor building spray and cooling systems provide reactor building atmosphere cooling to limit post-accident pressure and temperature in the reactor building to less than the design values. In the event of a design-basis accident (DBA), TS LCO 3.6.5, Reactor Building Spray and Cooling Systems, provides assurance that the systems will perform their design functions to mitigate the consequences of a DBA. The TS LCO requires two reactor building cooling trains and two reactor building spray trains to be OPERABLE during Modes 1 and 2.
2.1.3 Emergency Feedwater (EFW) System The EFW system automatically supplies feedwater to the steam generators to remove decay heat from the reactor coolant system upon the loss of normal feedwater supply. TS LCO 3.7.5, Emergency Feedwater (EFW) System, provides assurance that the EFW system will perform its design function to mitigate the consequences of events that could result in overpressurization of the reactor coolant pressure boundary. Two independent trains are required to be OPERABLE to ensure the availability of residual heat removal capability.
2.1.4 Alternating Current Sources - Operating The unit Class 1E alternating current (AC) electrical power distribution system AC sources consist of the offsite power sources (preferred and alternate power sources) and the onsite standby power sources (emergency diesel generators). TS LCO 3.8.1, AC Sources -
Operating, requires two qualified circuits between the offsite transmission network and the onsite Class 1E electrical distribution system and separate and independent diesel generators for each train (Emergency Diesel Generators 1 and 2) to ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence or a postulated DBA.
2.1.5 Inverters - Operating The inverters are the preferred source of power for the 120 volt-AC (VAC) buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the bus. The inverters are normally powered from the 125 volt-direct current electrical power system. TS LCO 3.8.7, Inverters - Operating, ensures the availability of AC electrical power for the instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.
2.1.6 Distribution Systems - Operating The onsite safeguards AC and direct current (DC) electrical power distribution systems are divided by train into two redundant and independent electrical power distribution subsystems.
TS LCO 3.8.9, Distribution Systems - Operating, requires that the required power distribution subsystems ensure the availability of AC, DC, and 120 VAC bus electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The AC, DC, and 120 VAC bus electrical power distribution subsystems are required to be OPERABLE.
2.2 Proposed TS Changes
The licensee proposed to delete the following statement from TS 1.3:
Example 1.3-3 illustrates one use of this type of Completion Time.
The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.
In addition, in Example 1.3-3, the licensee proposed to delete the AND 10 days from discovery of failure to meet the LCO from the CT of Conditions A and B.
Also, the licensee proposed to delete the following discussion from TS 1.3:
The Completion Times of Conditions A and B are modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase from discovery of failure to meet the LCO is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal time zero for beginning the Completion Time clock. In this instance, the Completion Time time zero is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.
The licensee proposed to replace the paragraph above with the following:
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
The licensee also proposed to delete the second CTs associated with the following TS LCO required actions:
TS 3.6.5, Required Actions A.1 and B.1 TS 3.7.5, Required Actions A.1 and B.1 TS 3.8.1, Required Actions A.3, and B.4 TS 3.8.7, Required Action A.1 (see variation below)
TS 3.8.9, Required Actions A.1, B.1, and C.1 2.3 The Licensees Variations from TSTF-439 In its application dated March 25, 2019, the licensee identified the following variations from TSTF-439:
The ANO-1 TS governing the Reactor Building Spray System is numbered 3.6.5.
The applicable TSTF-439 markup page from NUREG 1430, Standard Technical Specifications for Babcock & Wilcox Plants, Revision 4, is numbered 3.6.6 and uses the terminology containment in lieu of the ANO-1 noun name of reactor building. In addition, information may be relocated from one TS page to another in order to optimize space usage. While such relocation may involve deletion of unnecessary continuation statements, no technical changes are made when relocating information. Entergy considers these differences to be administrative in nature. Subsequently, TSTF-439 remains applicable to ANO-1 in light of these differences.
The listing of affected ANO-1 TS in Section 2.1 above are consistent with those listed in TSTF-439 with the exception of TS 3.8.7, which TSTF-439 does not include. This is because Revision 4 of NUREG 1430 does not contain a second Completion Time in the respective Inverter TS 3.8.7. The ANO-1 TSs were converted to the NUREG 1430, Revision 1, standard in October 2001.
Revision 1 of NUREG 1430 did not contain a second Completion Time for TS 3.8.7. In the Reference 3 of the Entergy letter dated August 23, 2001 (i.e., the 7th letter associated with [ANO-1 TS] conversion to NUREG 1430),
Entergy added the subject second Completion Time, although there is no documented discussion regarding the reason for this addition. Nevertheless,
removal of this second Completion Time remains consistent with the intent of TSTF-439 and, therefore, is considered appropriate.
The NRC staffs evaluation of the licensees variations is discussed in Section 3.0 of this safety evaluation.
2.4 Regulatory Requirements and Guidance The NRCs regulatory requirements related to the content of the TSs are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, and require, in part, that a summary statement of the bases for such specifications shall be included by applicants for a license authorizing operation of a production or utilization facility.
Specifically, the requirements for TS content in 10 CFR 50.36(c) include the following categories related to facility operation: (1) safety limits, limiting safety systems settings, and control settings; (2) LCOs; (3) surveillance requirements; (4) design features; and (5) administrative controls.
The regulation in 10 CFR 50.36(c)(2)(i), states, in part:
Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
The regulation in 10 CFR 50.36(c)(3), Surveillance requirements, states that:
Surveillance requirements are requirements related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The regulation in 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants (the maintenance rule), provides performance-based requirements to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.
In NUREG-1430, Standard Technical Specifications [STS], Babcock & Wilcox, Plants Revision 4 (ADAMS Accession No. ML12100A177), the guidance states, in part, that a second CT was included in the STS for certain required actions to establish a limit on the maximum time allowed for any combination of conditions that would result in a single continuous failure to meet the LCO. The intent of the second CT was to preclude entry into and out of the actions for an indefinite period of time without meeting the LCO. The second CT provides a limit on the amount of time the LCO would not be met for various combinations of conditions. As explained above, TSTF-439, Revision 2, deletes these second CTs from the affected STS required actions.
3.0 TECHNICAL EVALUATION
Second CTs (such as limits on the period of time from discovery of the failure to meet the LCO) were specified for certain TSs to prevent repeated entry into and exit from alternating TS
required actions. Administrative controls will replace second CTs as described in the license amendment request (LAR) dated March 25, 2019. In addition, two programs provide a strong disincentive to licensees continuing operation with alternating required actions as described above. These programs are the maintenance rule program and the NRCs reactor oversight process (ROP).
The NRC staff noted that the licensees original application stated, The risk assessments are conducted using the procedures and guidance endorsed by RG 1.182. RG 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. RG 1.182 was previously withdrawn because it was redundant because the subject matter was included in Revision 3 of RG 1.160. The withdrawal of RG 1.182 was published in the Federal Register on November 27, 2012 (77 FR 70846). The Federal Register notice stated that the withdrawal of RG 1.182 did not alter any prior or existing licensing commitments based on its use, did not constitute backfitting as defined in 10 CFR 50.109 (the Backfit Rule), and was not otherwise inconsistent with the issue finality provisions in 10 CFR Part 52. In its supplement to the LAR, dated November 18, 2019, the licensee clarified that its prior reference to RG 1.182 in its original application should now refer to RG 1.160 and NUMARC 93-01, Revision 4A.
In the LAR [as clarified per the preceding paragraph in its supplement dated November 18, 2019], the licensee addressed the application of the maintenance rule:
In accordance with 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by [Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Regulatory Guide 1.160 endorses the Revision 4A of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.] These documents address general guidance for conduct of the risk assessments, quantitative and qualitative guidelines for establishing risk management actions, and provide example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and the determination that the proposed maintenance is acceptable.
The licensee added that this comprehensive maintenance rule program provides much greater assurance of safe plant operation than the second CTs in the affected TSs.
In the LAR, the licensee states, in part, the following regarding the ROP:
Another program that acts to prevent indefinite application of a TS LCO is the Reactor Oversight Process (ROP). Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, describes the tracking and reporting of performance indicators to support the NRC ROP. The NEI document is endorsed by Regulatory Issue Summary (RIS) 2001-11, Voluntary Submission of Performance Indicator Data. NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC Sources, which encompasses the AC Sources and Distribution
System LCOs, and the Emergency (Auxiliary) Feedwater system. Extended unavailability of these systems due to multiple entries into the actions would affect the NRCs evaluation of the licensees performance under the ROP.
In the LAR, the licensee also states, in part, the following regarding administrative controls:
In addition to the aforementioned programs, a requirement is proposed to be added to Section 1.3 of the TSs that would require licensees to establish administrative controls in order to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls are intended to consider plant risk and limit the maximum contiguous time of failing to meet the LCO. When considered in conjunction with the regulatory processes discussed above, the proposed addition to TS Section 1.3 provides an equivalent or superior level of plant safety without the unnecessary complication of the second Completion Times (with consideration of TSTF-505 as discussed previously [in the LAR]).
ANO has procedural guidance for LCO tracking. As part of the implementation process for this TS change, Entergy plans to add statements similar to the following to the appropriate procedure:
It is possible to alternate between TS Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so is inconsistent with the basis of the Completion Times. Therefore, the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO shall be limited.
Prior to the promulgation of 10 CFR 50.65, TSs were the primary requirements governing operations, including what equipment must normally be in service, how long equipment can be out of service, compensatory actions, and surveillance testing to demonstrate equipment readiness. The goal of TSs is to provide adequate assurance of the availability and reliability of equipment needed to prevent, and if necessary, mitigate accidents and transients. The maintenance rule supports this same goal by requiring a comprehensive process for performance and condition monitoring activities. As required by 10 CFR 50.65, the licensee assesses and manages the inoperable equipment; however, the rule also considers all inoperable risk-significant equipment. Under the TSs, the CT for one system within an LCO is not generally affected by inoperable equipment in another LCO. However, the second CT influenced the CT for one system based on the condition of another system, but only if the two systems were required by the same LCO. Plant-specific maintenance rule programs implement risk-based configuration management programs that augment the deterministic CTs in the TSs.
The performance and condition monitoring activities required by 10 CFR 50.65 identify poor maintenance practices that would result from multiple entries into the actions of the TSs, which would contribute to unacceptable unavailability of these SSCs.
The NRC staff finds the proposed changes to TS 1.3 acceptable because administrative control requirements added in Example 1.3-3 of the TSs would limit the maximum time allowed for any combination of conditions that results in a single contiguous occurrence of failing to meet the LCO and would ensure that CTs are not inappropriately extended. In addition, the licensees maintenance rule program requires the licensee to monitor the performance or conditions of
SSCs in a manner sufficient to provide reasonable assurance that SSCs can fulfill their specified safety functions, and thus, prevent indefinite operation without restoration of the systems.
The LAR identified two variations from TSTF-439 as stated in Section 2.3 of this safety evaluation. The first variation is associated with the terminology differences in LCO 3.6.5 between the ANO-1, Unit 1 TSs and the STS. The NRC staff determined that the variation is administrative in nature and does not affect the applicability of TSTF-439. Therefore, the NRC staff finds the variation acceptable.
The second variation concerns the proposed deletion of the second CT in TS 3.8.7, which TSTF-439 does not include. The licensee stated that Revision 4 of NUREG-1430 does not contain a second CT in the respective Inverter TS 3.8.7. The ANO-1 TSs were converted to the NUREG-1430, Revision 1, standard in October 2001. However, Revision 1 of NUREG-1430 did not contain a second CT for TS 3.8.7. The NRC staffs review of this variation finds it to be acceptable because, as discussed above in this safety evaluation, the maximum time allowed for LCO 3.8.7 would not be inappropriately extended. Therefore, the proposed deletion of the second CT requirement of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from LCO 3.8.7 is consistent with the intent of the approved TSTF-439 and is in accordance with NUREG-1430, and therefore, is acceptable.
The proposed change deletes the second CT associated with TSs 3.6.5, 3.7.5, 3.8.1, 3.8.7, and 3.8.9. These additional secondary CTs were specified for these instances to prevent repeated entry and exit from alternating TS-required actions. Administrative controls will replace second CTs as described in the LAR.
The NRC staff finds the proposed deletion of the second CTs listed above acceptable because multiple, continuous entries into TS conditions, without meeting the LCO, would be adequately controlled by the licensees administrative controls and configuration risk management programs, which were implemented to meet the requirements of the maintenance rule to assess and manage risk, and would be controlled by the use and application convention discussed in Section 1.3 of the TSs. In addition, the NRC staff finds that the ROP, coupled with the maintenance rule, provide adequate assurance against inappropriate use of combinations of TS conditions that result in a single contiguous occurrence of failing to meet the LCO.
Accordingly, the NRC staff finds the proposed TS changes acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Arkansas State official was notified of the proposed issuance of the amendment on February 28, 2020. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, published in the FR on June 4, 2019 (84 FR 25836), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to
10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. Grover Date: March 16, 2020
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NAME TWengert PBlechman VCusumano DATE 03/04/2020 02/26/2020 11/20/2019 OFFICE OGC NLO*
NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME AGhosh Naber JDixon-Herrity TWengert DATE 03/12/2020 03/16/2020 03/16/2020