ML20262H075
| ML20262H075 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/17/2020 |
| From: | Thomas Wengert NRC/NRR/DORL/LPL4 |
| To: | Keele R Entergy Nuclear Operations |
| Wengert T | |
| References | |
| L-2019-LLA-0284 | |
| Download: ML20262H075 (6) | |
Text
From:
Wengert, Thomas Sent:
Thursday, September 17, 2020 1:09 PM To:
Keele Jr, Riley D Cc:
BICE, DAVID B (ANO); Dixon-Herrity, Jennifer
Subject:
ANO-2 Final RAI #2 RE: License Amendment Request Concerning Proposed Technical Specification Additions, Deletions, and Relocations (EPID L-2019-LLA-0284)
Attachments:
ANO-2 Final RAI #2 - LAR for TS Additions-Deletions-Relocations.pdf On September 17, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff sent Entergy Operations, Inc. (Entergy) the draft Request for Additional Information (RAI) identified below. This RAI relates to the December 16, 2019, license amendment request (LAR) that proposed changes to several Arkansas Nuclear One, Unit 2 technical specification (TS) requirements by the addition, deletion, or relocation of certain TS Limiting Conditions for Operation (LCOs), Actions, and Surveillance Requirements (SRs).
Entergy subsequently informed the NRC staff that the information requested was understood and that no additional clarification of the RAI was necessary. A publicly available version of this final RAI (attached with Draft removed) will be placed in the NRCs Agencywide Documents Access and Management System (ADAMS). As agreed, please provide a response to this RAI within 30 days of this correspondence.
From: Wengert, Thomas Sent: Thursday, September 17, 2020 8:30 AM To: Keele Jr, Riley D Cc: 'BICE, DAVID B (ANO)' ; Dixon-Herrity, Jennifer
Subject:
ANO-2 Draft RAI #2 RE: License Amendment Request Concerning Proposed Technical Specification Additions, Deletions, and Relocations (EPID L-2019-LLA-0284)
By application dated December 16, 2019, as supplemented by letter dated June 17, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML19350B324 and ML20169A558, respectively), Entergy Operations, Inc. (the licensee) submitted a license amendment request (LAR), proposing various revisions to the Arkansas Nuclear One, Unit 2 (ANO-2) technical specifications (TSs). The proposed changes would revise several TS requirements by the addition, deletion, or relocation of certain TS Limiting Conditions for Operation (LCOs), Actions, and Surveillance Requirements (SRs). Relocated TSs would be placed in the ANO-2 Technical Requirements Manual or the associated TS Bases.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information, as described in the attached request for additional information (RAI), is required for the staff to complete its review of this application. This RAI is identified as draft at this time to confirm your understanding of the information that the NRC staff needs to complete the evaluation.
Please contact me if you would like to set up a conference call with the NRC staff to clarify this request for information. In addition, lets discuss the timing for your response to this request.
Tom Wengert Project Manager - Arkansas Nuclear One NRR/DORL/LPL4 (301) 415-4037
Hearing Identifier:
NRR_DRMA Email Number:
792 Mail Envelope Properties (DM6PR09MB4759B74340DCA8B53C73EF188F3E0)
Subject:
ANO-2 Final RAI #2 RE: License Amendment Request Concerning Proposed Technical Specification Additions, Deletions, and Relocations (EPID L-2019-LLA-0284)
Sent Date:
9/17/2020 1:09:14 PM Received Date:
9/17/2020 1:09:00 PM From:
Wengert, Thomas Created By:
Thomas.Wengert@nrc.gov Recipients:
"BICE, DAVID B (ANO)" <DBICE@entergy.com>
Tracking Status: None "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>
Tracking Status: None "Keele Jr, Riley D" <rkeele@entergy.com>
Tracking Status: None Post Office:
DM6PR09MB4759.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2611 9/17/2020 1:09:00 PM ANO-2 Final RAI #2 - LAR for TS Additions-Deletions-Relocations.pdf 126151 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
1 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST CONCERNING PROPOSED TECHNICAL SPECIFICATION DELETIONS, ADDITIONS, AND RELOCATIONS ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-368 By application dated December 16, 2019, as supplemented by letter dated June 17, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML19350B324 and ML20169A558, respectively), Entergy Operations, Inc. (the licensee) submitted a license amendment request, proposing various revisions to the Arkansas Nuclear One, Unit 2 (ANO-2) technical specifications (TSs). The proposed changes revise several TS requirements by the addition, deletion, or relocation of certain TS Limiting Conditions for Operation (LCOs), Actions, and Surveillance Requirements (SRs). Relocated TSs would be placed in the ANO-2 Technical Requirements Manual or the associated TS Bases. The Nuclear Regulatory Commission (NRC) staff has reviewed the submittals and determined that additional information is needed to complete the review, as described below.
Regulatory Basis GDC 60, Control of Releases of Radioactivity Materials to the Environment, states:
The nuclear power unit design shall include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences.
Sufficient holdup capacity shall be provided for retention of gaseous and liquid effluents containing radioactive materials, particularly where unfavorable site environmental conditions can be expected to upon the release of such effluents to the environment.
GDC 64, Monitoring Radioactivity Releases, states:
Means shall be provided for monitoring the reactor containment atmosphere, spaces containing components for recirculation of LOCA fluids, effluent discharge paths, and the plant environs for radioactivity that may be released from normal operation, anticipated operational occurrences, and from postulated accidents.
=
Background===
In Section 2.4, Description of the Proposed Change, of the application dated December 16, 2019, the licensee stated, in part, that TSs 3.11.1, Liquid Holdup Tanks, 3.11.12, Gas Storage Tanks, and 3.11.13, Explosive Gas Mixture, would be relocated to new TS 6.5.8, Explosive
2 Gas and Storage Tank Radioactivity Monitoring Program, and that the respective TS Bases would be deleted.
In the description of these proposed changes (Page 26 of the enclosure), the licensee stated, in part:
The limit placed on GRW [gaseous radwaste] storage tanks is established such that, in the event of an uncontrolled release of the tanks contents, the resulting total body exposure to a member of the public at the nearest exclusion area boundary will not exceed 0.5 rem. This is consistent with Branch Technical Position [BTP] ETSB 11-5, Postulated Radioactivity Release due to Waste Gas System Leak or Failure (Reference 19). [emphasis added]
Issues
- 1.
Reference 19 of the application identifies NRC Branch Technical Position ETSB 11-5, Revision 3, Postulated Radioactive Release due to Waste Gas System Leak or Failure,
([ADAMS Accession No.] ML052350110), July 1981. However, the identified ADAMS number does not correspond BTP 11-5, Rev. 3, July 1981. BTP ETSB 11-5, Rev. 0 (July 1981) is located at ADAMS Accession No. ML052350105), pages 11.3-11 to 11.3-16.
- 2.
As noted in the licensees application, the licensee is proposing to adopt a new program in TS 6.5.8, that would replace TSs 3.11.1, 3.11.2, and 3.11.3. The licensee noted that the TS Bases for the three replaced TSs would also be deleted. The TS Bases for existing TS 3.11.2, currently states:
Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that, in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to a MEMBER OF THE PUBLIC at the nearest EXCLUSION AREA boundary will not exceed 0.5 rem. This is consistent with Branch Technical Position ETSB 11-5 in NUREG-0800, July 1981.
Proposed TS 6.5.8 states the following, in part:
The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, Postulated Radioactive Release due to Waste Gas System Leak or Failure.
There are no new TS Bases associated with proposed TS 6.5.8. Proposed TS 6.5.8 does not identify the specific version (i.e., Revision No. and date) of BTP ETSB 11-5.
3 Request for Additional Information (RAI)
RAI-ARCB-1 Confirm the specific version and revision of BTP ETSB 11-5 that ANO-2 will be adopting upon implementation of this license amendment request.
RAI-ARCB-2 Modify proposed TS 6.5.8, as appropriate, to include the specific version (revision and date) of BTP ETSB 11-5 that will be applicable to the respective requirements in this TS section.