ML25079A328
| ML25079A328 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/19/2025 |
| From: | Dennis Galvin NRC/NRR/DORL/LPL4 |
| To: | Keele R Entergy Operations |
| Galvin D, NRR/DORL/LPL4 | |
| References | |
| EPID L-2024-LLA-0092 | |
| Download: ML25079A328 (1) | |
Text
From:
Dennis Galvin To:
Riley Keele, Jr. (rkeele@entergy.com)
Cc:
Couture III, Philip; Clark, Robert; Tony Nakanishi
Subject:
Arkansas Nuclear 1 - Request for Additional Information - Request for Review and Approval Changes to SAR and to a Confirmatory Order - PZR HTR Emergency Power Supply (EPID L-2024-LLA-0092)
Date:
Wednesday, March 19, 2025 5:24:00 PM Attachments:
ANO LAR Pressurizer Heater Order RAIs Issued 2025-03-19.pdf
Dear Mr. Keele,
By application dated July 2, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML24184B775), as supplemented by letter dated February 26, 2025 (ML25057A318), Entergy Operation, Inc. (Entergy, the licensee) requested an amendment to the Renewed Facility Operating License Number DPR-51 for Arkansas Nuclear One, Unit 1 (ANO-1). The proposed changes would modify the ANO-1 Safety Analysis Report (SAR) and the Confirmatory Order to implement all Category A lessons learned requirements by January 31, 1980, for ANO-1. The proposed changes would add to the SAR and the confirmatory order statements for performing manual actions at 120 VAC instrument panels Y01 and Y02 outside the control room to restore power to the pressurizer low-low level interlock.
The Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete its review. The requests for additional information (RAIs) were transmitted to the licensee in draft form on March 6, 2025. A clarification call was held with your staff on March 19, 2025, and the licensee agreed to provide responses to the RAls by April 18, 2025. The NRC staff agrees with this date.
Sincerely,
Dennis Galvin Project Manager / Agency 2.206 Petition Coordinator U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Plant Licensing Branch IV 301-415-6256
1 DRAFT REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST FOR REVIEW AND APPROVAL CHANGES TO SAR AND TO A CONFIRMATORY ORDER - PRESSURIZER HEATER EMERGENCY POWER SUPPLY ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 05000313
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Background===
By application dated July 2, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML24184B775), as supplemented by letter dated February 26, 2025 (ML25057A318), Entergy Operations, Inc. (Entergy, the licensee) requested an amendment to the Renewed Facility Operating License Number DPR-51 for Arkansas Nuclear One, Unit 1 (ANO-1). The proposed changes would modify the ANO-1 Safety Analysis Report (SAR) and the January 2, 1980, Confirmatory Order (ML021220215) to allow an alternate means of compliance with the post TMI-2 recommendation that any changeover of the pressurizer heaters from normal offsite power to emergency onsite power is to be accomplished manually in the control room. The proposed changes would allow for certain loss of offsite power (LOOP) events the performance of manual actions at 120 VAC instrument panels Y01 and Y02 outside the control room to restore power to the pressurizer low-low level interlock to allow operation of required pressurizer heaters on emergency onsite power.
Regulatory BasisSection IV of the Confirmatory Order ordered in part The Licensee by January 31, 1980, implement all "Category A" requirements referred to in Part II of this Order,Section II of the Confirmatory Order referred to requirements in three documents:
NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-term Recommendations", dated July 1979 (ML090060030), which sets forth measures identified by the NRC TMI-2 Lessons Learned Task Force to be taken in the short-term to reduce the likelihood of accidents and to improve emergency preparedness in responding to accidents. Section 2.1.1 of NUREG-0578 provides recommendations regarding pressurizer heaters.
Generic Letter 79-40, Followup Actions Resulting from the NRC Staff Reviews Regarding the Three Mile Island Unit 2 Accident, dated September 13, 1979 (ML112990325), which transmitted to licensees "Category A" requirements, which were actions at operating nuclear power plants that require prompt implementation to provide continued assurance of public health and safety. Specifically, Enclosure 6 of Generic Letter 79-40, designates the recommendations in Section 2.1.1 of NUREG-0578 as Implementation Category A, with an implementation completion date of January 1, 1980.
2 Generic Letter 79-56, Discussion of Lessons Learned Short Term Requirements, dated October 30, 1979 (ML031320403), which provided clarifications to the requirements in NUREG-0578. Specifically, Section 2.1.1 of the enclosure to Generic Letter 79-56 identified four positions and seven clarifications regarding pressurizer heaters. The fourth clarification states:
- 4. Any change-over of the heaters from normal offsite power to emergency onsite power is to be accomplished manually in the control room.
NUREG-0737, Clarification of TMI Action Plan Requirements, dated November 1980 (ML102560051), identifies all post-TMI requirements which had been approved for implementation by the Commission at that time. Most of the items in NUREG-0737 had been previously issued as requirements as prior correspondence, though some new requirements were issued in NUREG-0737. NUREG-0737, Item II.E.3.1, Emergency power for pressurizer heaters, is the designation for the requirements in Section 2.1.1 of NUREG-0578. The requirements in NUREG-0737, Item II.E.3.1 are unchanged from the clarification of Section 2.1.1 of Generic Letter 79-56, including the fourth clarification item.
The staff used the guidelines in Section 2.7.8, Relaxation, Withdrawal, or Rescission of Orders, of Part I, Enforcement Process, of the Enforcement Manual, (https://www.nrc.gov/about-nrc/regulatory/enforcement/guidance.html#manual) to review the licensees request to modify the Confirmatory Order. Section 2.7.8 states that the NRC staff may relax, withdraw, or rescind conditions of an order and provides criteria that should be considered when evaluating the licensees good cause justification.
Issue:
The licensee requests in part to modify requirements imposed by the January 2, 1980, confirmatory order, specifically the TMI requirements that any change-over of the pressurizer heaters from normal offsite power to emergency onsite power is to be accomplished manually in the control room. In 2015, the licensee identified that during certain loss of offsite power (LOOP) events, power would be lost to the pressurizer low-low level heater interlock. If the interlock is de-energized, the required heaters cannot be operated. The design of ANO-1 requires manual operator actions outside the control room to restore power to the pressurizer low-low level heater interlock to allow the operation of the minimum TS required pressurizer heaters. Thus, the change-over of the pressurizer heaters from normal offsite power to emergency onsite power cannot be accomplished from the control room for all LOOP events. Therefore, the licensee is requesting a modification of the confirmatory order to allow an alternative to the TMI requirements. The NRC staff has identified questions with (a) the confirmatory order requirements the licensee is proposing to change and (b) the justification for the change.
Question 1:
- a. The licensee proposes to make changes to the January 2, 1980, Confirmatory Order with a proposed change to NUREG-0737 Item II.3.E.1. As noted in the regulatory basis, NUREG-0737 is not referenced in the confirmatory order as the confirmatory order was issued prior to NUREG-0737. Therefore, the license is not requesting an actual change to the confirmatory order. The licensee is requested to describe a proposed change to a document incorporated into the confirmatory order, including clearly describing the relationship of the document to the order and the specific ordered language.
3
- b. The process for a licensee to request a relaxation, withdrawal, or rescission of a requirement in an order is described in Section 2.7.8 of the Enforcement Manual. The licensee request does not provide a specific good cause justification for its request or otherwise address the guidance in Section 2.7.8 of the Enforcement Manual. The licensee is requested to provide a specific good cause justification consistent with Section 2.7.8 of the Enforcement Manual for the proposed change to the confirmatory order. This justification may refer to the justification for the proposed change to the ANO-1 SAR.