2CAN042401, Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications

Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications

ML24095A063
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/04/2024
From:	Couture P Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
2CAN042401
Download: ML24095A063 (1)

Text

Phil Couture Sr. Manager Fleet Regulatory Assurance - Licensing 601-368-5102

2CAN042401 10 CFR 50.90

April 4, 2024

ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications

NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) requests an amendment to the Arkansas Nuclear One, Unit 2 (ANO-2) Tec hnical Specifications (TS). This amendment corrects three obvious typographical errors.

These errors were inadvertently introduced into the TS by License Amendments 315 (Reference 1) and 326 (Reference 2). TS 6. 5.18, "Surveillance Frequency Control Program" Item c incorrectly refers to Surveillance Requirements (SR) 3.0.2 and 3.0.3 instead of the correct SR 4.0.2 and 4.0.3. TS 6.6.8, "Specific Activity" inadvertently combines the words "primary" and "coolant" in the last sentence of the paragraph. Since all of these errors were present in their respective notices to the public and were present during NRC review, correction of the errors does not fall within the scope of the guidance provided by SECY-96-238 (Reference 3); therefore, a license amendment request is required.

The enclosure contains the description and assessment for the request to revise the Technical Specifications to correct the typographical errors discussed above. Attachment 1 to the enclosure contains the mark-ups of the affected Technical Specification pages. Attachment 2 of the enclosure contains the clean, retyped Technical Specification pages.

Entergy has reviewed the information supporting a finding of no significant hazards consideration and the environment al considerations provided to the NRC in References 1 and 2.

The supplemental information provided in this letter does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration.

Furthermore, the supplemental information provided in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendments.

This letter contains no new regulatory commitments.

Entergy Operations, Inc. 1340 Echelon Parkway, Jackson, MS 39213 2CAN042401 Page 2 of 3

Entergy requests approval of the proposed license amendment by October 31, 2024, with the proposed changes implemented within 90 days of issuance of the amendment.

In accordance with 10 CFR 50.91, "Notice for Public Comment; State Consultation," Entergy is notifying the State of Arkansas of this amendment request by transmitting a copy of this letter and enclosures to the designated State Official.

If there are any questions or if additional information is needed, please contact Riley Keele, Manager, Regulatory Assurance, Arkansas Nuclear One, at 479-858-7826.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 4th day of April 2024.

Sincerely,

Phil Couture

PC/mar

Enclosure:

Evaluation of Proposed Change Attachments: 1. Technical Specification Page Markups

2. Retyped Technical Specification Pages

References:

1) NRC Letter to Entergy, "Arkansas Nuclear One, Unit 2 - Issuance of Amendment [315] RE: Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-425, Revision 3," (2CNA041904) (ADAMS Accession No. ML19063B948), dated April 23, 2019

2) NRC Letter to Entergy, "Arkansas Nuclear One, Units 1 and 2 and Waterford Steam Electric Station, Unit 3 - Issuance of Amendments Regarding Revision of Technical Specifications to Adopt TSTF-577,

'Revised Frequencies for Steam Generator Tube Inspections',"

(0CNA122101) (ADAMS Accession No. ML21313A008), dated December 8, 2021

3) NRC Policy Issue from James M. Taylor to the Commissioners -

SECY-96-238, "Proposed Guidance for Correction of Technical Specification Typographical Errors," (ADAMS Accession No. 9611250030), dated November 19, 1996

2CAN042401 Page 3 of 3

cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official Enclosure

2CAN042401

Evaluation of Proposed Change Enclosure 2CAN042401 Page 1 of 4

Evaluation of Proposed Change

1.0

SUMMARY

DESCRIPTION

The proposed amendment corrects obvious typographical errors in the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS).

2.0 DETAILED DESCRIPTION

The ANO-2 TS incorporated TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - RITSTF [Risk-Informed Technical Specification Task Force] Initiative 5b" in Amendment 315 (Reference 1). ANO-2 has not yet adopted NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants" (Reference 2) and the current TS are based on NUREG-0212, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors" dated March 15, 1977 (Reference 3). Aside from significant format differences be tween the current ANO-2 TS and NUREG-1432, the numbering scheme for specificati ons and surveillance requirements (SR) is different. In the current TS, Limiting Conditions for Operation (LCOs) begin with the number three (3), and SRs begin with the number four (4). In the Standard Technical Specifications (STSs),

LCOs and SRs begin with the number three (3). TSTF travelers are written based on the Standard TS (NUREG-1430 through NUREG-1434), and as such, TSTF-425 referred to SRs using the NUREG-1432 SR numbering schem e. In the ANO-2 license amendment request (LAR) for TSTF-425 (Reference 4), specification 6.5.18, "Surveillance Frequency Control Program," Item c states:

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

This is an obvious typographical error since the current ANO-2 TS do not have SR 3.0.2 and 3.0.3. The correct verbiage is as follows [emphasis added]:

The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

A review of the current TS for other occurrences of this error was performed, and no other occurrences were found.

This amendment request also seeks to correct a missing space in the last sentence of TS 6.6.8, "Specific Activity." The current TS states:

and (5) The time duration when the specific activity of the primarycoolant exceeded the radioiodine limit.

There is currently no space between the words "primary" and "coolant." The phrase should state [emphasis added]:

and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

Enclosure 2CAN042401 Page 2 of 4

3.0 TECHNICAL EVALUATION

The proposed amendment contains no technical changes. All of the proposed changes are administrative. These changes are consistent with the intent of what the Nuclear Regulatory Commission (NRC) has already approved for these pages.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

10 CFR 50.36, "Technical Specifications"

The NRC's regulatory requirements related to the content of the Technical Specifications (TS) are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications." This regulation requires that the TS include items in the following five specific categories: (1) safety limits, limiting safety system settings, and limiting control se ttings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls.

Per 10 CFR 50.36(c)(2)(ii), a TS LCO must be established for each item meeting one or more of the following criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4: A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Conclusion

Entergy has evaluated the proposed changes against the applicable regulatory requirements described above. The proposed amendment contains no technical changes; all of the proposed changes are administrative. Based on this evaluation, there is reasonable assurance that the health and safety of the public will remain unaffected following the approval of these proposed changes.

Enclosure 2CAN042401 Page 3 of 4

4.2 Precedent

Entergy finds that these type changes are consistent with the changes requested by Southern Nuclear for Plant Hatch in Reference 6.

4.3 No Significant Hazards Consideration Analysis

The proposed amendment corrects obvious typographical errors in the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS).

As required by 10 CFR 50.91(a), Entergy Operations, Inc. (Entergy) has evaluated the proposed changes to the ANO-2 TS and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards is presented below:

1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

The proposed amendment contains no technical changes. All of the proposed changes are administrative. These changes are consistent with the intent of what has already been approved by the Nuclear Regulatory Commission (NRC). There are no accidents affected by this change; therefore, there is no increase in the probability or consequences of an accident that has been previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

The proposed amendment contains no technical changes; all proposed changes are administrative. These changes are consistent with the intent of what has already been approved by the NRC. There are no accidents affected by this change; therefore, there is no possibility of a new or different kind of accident from any accident that has been previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

The proposed amendment contains no technical changes; all proposed changes are administrative. These changes are consistent with the intent of what has already been approved by the NRC. There are no accidents affected by this change; therefore, there is no reduction in the margin of safety for the plant.

Enclosure 2CAN042401 Page 4 of 4

4.4 Conclusions

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuan ce of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Entergy has evaluated the proposed change and determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. TSTF-425, Technical Specification Task Force - Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b, Revision 3, (ADAMS Accession No. ML090850642), dated March 2009

2. NRC NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants," Revision 5, (ADAMS Accession No. ML21258A421), dated September 2021

3. NRC NUREG-0212, "Standard Technical Spec ifications for Combustion Engineering Pressurized Water Reactors," Revision 0, (ADAMS Accession No. ML17266A003),

dated March 15, 1977

4. Entergy Letter to NRC, Arkansas Nuclear One, Unit 2 - Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)," (2CAN021802) (ADAMS Accession No. ML18038B354), dated February 6, 2018

5. NRC Policy Issue from James M. Taylor to the Commissioners - SECY-96-238, "Proposed Guidance for Correction of Technical Specification Typographical Errors,"

(ADAMS Accession No. 9611250030), dated November 19, 1996

6. Southern Nuclear Operating Company, Inc. Letter to NRC, "Edwin I. Hatch Nuclear Plant Request to Revise Typographical Error in Unit 1 Operating License and in Unit 2 Technical Specifications, and to add STAGGERED TEST BASIS to Unit 1 and Unit 2 Technical Specifications," (ADAMS Accession No. ML15216A602), dated August 4, 2015 Attachment 1

2CAN042401

Technical Specification Page Markups

[2 pages]

ADMINISTRATIVE CONTROLS

6.5.17 Metamic Coupon Sampling Program

A coupon surveillance program will be implemented to maintain surveillance of the Metamic absorber material under the radiation, chemical, and thermal environment of the SFP. The purpose of the program is to establish the following:

• Coupons will be examined on a two year basis for the first three intervals with the first coupon retrieved for inspection being on or before October 31, 2009 and thereafter at increasing intervals over the service life of the inserts.

• Measurements to be performed at each inspection will be as follows:

a. Physical observations of the surface appearance to detect pitting, swelling or other degradation,

b. Length, width, and thickness measurements to monitor for bulging and swelling

c. Weight and density to monitor for material loss, and

d. Neutron attenuation to confirm the B-10 concentration or destructive chemical testing to determine the boron content.

• The provisions of SR 4.0.2 are applicable to the Metamic Coupon Sampling Program.

• The provisions of SR 4.0.3 are not applicable to the Metamic Coupon Sampling Program.

6.5.18 Surveillance Frequency Control Program

This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 34.0.2 and 34.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

ARKANSAS - UNIT 2 6-18a Amendment No. 273,315, ADMINISTRATIVE CONTROLS

6.6.8 Specific Activity

The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded the results of one analysis after the radioiodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primarycoolant exceeded the radioiodine limit.

Insert space between "primary" and "coolant"

ARKANSAS - UNIT 2 6-22a Amendment No. 326, Attachment 2

2CAN042401

Retyped Technical Specification Pages

[2 Pages]

ADMINISTRATIVE CONTROLS

6.5.17 Metamic Coupon Sampling Program

A coupon surveillance program will be implemented to maintain surveillance of the Metamic absorber material under the radiation, chemical, and thermal environment of the SFP. The purpose of the program is to establish the following:

• Coupons will be examined on a two year basis for the first three intervals with the first coupon retrieved for inspection being on or before October 31, 2009 and thereafter at increasing intervals over the service life of the inserts.

• Measurements to be performed at each inspection will be as follows:

a. Physical observations of the surface appearance to detect pitting, swelling or other degradation,

b. Length, width, and thickness measurements to monitor for bulging and swelling

c. Weight and density to monitor for material loss, and

d. Neutron attenuation to confirm the B-10 concentration or destructive chemical testing to determine the boron content.

• The provisions of SR 4.0.2 are applicable to the Metamic Coupon Sampling Program.

• The provisions of SR 4.0.3 are not applicable to the Metamic Coupon Sampling Program.

6.5.18 Surveillance Frequency Control Program

This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

ARKANSAS - UNIT 2 6-18a Amendment No. 273,315, ADMINISTRATIVE CONTROLS

6.6.8 Specific Activity

The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded the results of one analysis after the radioiodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

ARKANSAS - UNIT 2 6-22a Amendment No. 326,