ML23296A100
| ML23296A100 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear, Waterford  |
| Issue date: | 10/24/2023 |
| From: | Entergy Operations |
| To: | Lingham S NRC/NRR/DORL/LPL4 |
| Wengert T | |
| References | |
| EPID L-2023-LRM-0081 | |
| Download: ML23296A100 (1) | |
Text
Arkansas Nuclear One Unit 2 Waterford 3 Pre-Submittal Meeting to Adopt Moderator Temperature Coefficient Tech Spec Change October 24, 2023
2 Agenda
Background
Current Requirements Proposed Changes Discussion of the Change Precedent Timeline for Submittal Open Discussion
3 Background
- Arkansas Nuclear One Unit 2 (ANO2) and Waterford 3 (WF3) have Technical Specifications (TS) based on NUREG-0212.
- The NUREG-0212 Technical Specifications provide more information than is generally contained in the Improved Standard Technical Specification (ISTS).
- The TS typically do not specify how a surveillance should be performed, only that a parameter should be within limits.
- The TS do not specify references to specific topical reports that are used.
- The proposed License Amendment Request (LAR) will more closely align the ANO2 and WF3 Moderator Temperature Coefficient (MTC) TSs with the structure in NUREG-1432.
4 Current Requirements - ANO2 ANO2 MTC Technical Specification is documented in TS 3.1.1.4
- The Limiting Condition for Operation (LCO) for ANO2 is similar to the ISTS in function with some minor wording differences.
- The current applicability includes a footnote (*) for Keff 1.0 in MODE 2.
- The current end state mode in the Action statement is referred to by name.
5 Current Requirements - ANO2 ANO2 MTC Technical Specification is documented in TS 3.1.1.4.
- The surveillance requirement (SR) states that MTC shall be confirmed by measurement.
- SR 4.1.1.4.2 specifies that the surveillance is performed prior to and above 5% rated thermal power (RTP).
6 Current Requirements - ANO2 ANO2 MTC Technical Specification is documented in TS 3.1.1.4.
- SR 4.1.1.4.1 and SR 4.1.1.4.2 are modified by notes that allow prediction to verify MTC in accordance with WCAP-16011-P-A.
7 Current Requirements - WF3 WF3 MTC Technical Specification is documented in TS 3.1.1.3.
- The current applicability includes a footnote (1) for Keff 1.0 in MODE 2.
- The current end state mode in the Action statement is referred to by name.
8 Current Requirements - WF3 WF3 MTC Technical Specification is documented in TS 3.1.1.3.
- The SR states that MTC shall be confirmed by measurement.
- SR 4.1.1.3.2 specifies that the surveillance is performed prior to 5% RTP, greater than 15%,
and at any power.
9 Current Requirements - WF3 WF3 MTC Technical Specification is documented in TS 3.1.1.3.
- SR 4.1.1.3.1 and SR 4.1.1.3.2 are modified by notes that allow prediction to verify MTC in accordance with WCAP-16011-P-A.
10 Proposed Changes ANO2 and WF3 will adopt the structure of the ISTS (ANO2 example is shown).
11 Discussion of the Change
- Current SRs are structured using NUREG-0212. This structure specifies a specific surveillance procedure will be used to verify the MTC.
- Current SRs contain the word measured, which precludes using another procedure to verify that the surveillances are met.
- Revising the wording in SRs from measured to verified is consistent with the ISTS.
- Using the word verified will allow the use of other procedures to verify the surveillances are met.
12 Discussion of the Change
- The industry has worked on several initiatives to reduce the number of times that MTC is measured in the plant.
- South Texas Project (STP) submitted a LAR in 2021 (ML21014A213) that was withdrawn (ML21237A056).
- Entergy is not requesting approval of a new procedure that will be used to verify MTC.
- At this time, Entergy is not making any change to the procedure that is used to verify the MTC.
- Future changes to the surveillance procedures will be assessed in accordance with 10 CFR 50.59.
13 Precedent NUREG-1432, Standard Technical Specifications for Combustion Engineering Plants.
14 Timeline for Submittal
- Submittal to NRC - 1st quarter 2024
- Requesting normal NRC approval schedule
15 CLOSING REMARKS