2CAN092002, Response to Second Request for Additional Information Related to License Amendment Request Associated with Technical Specification Deletions, Additions, and Relocations

Response to Second Request for Additional Information Related to License Amendment Request Associated with Technical Specification Deletions, Additions, and Relocations

ML20266G333
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/22/2020
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN092002
Download: ML20266G333 (10)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 2CAN092002 September 22, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Response to Second Request for Additional Information Related to License Amendment Request Associated with Technical Specification Deletions, Additions, and Relocations Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 By letter dated December 16, 2019 (Reference 1), as supplemented by letter dated June 17, 2020 (Reference 3), Entergy Operations, Inc. (Entergy), requested NRC approval of a proposed change to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TSs) to enhance consistency with NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," Revision 4. During the course of review, the NRC determined additional information was required to complete the review process.

The NRC notified Entergy of the request for additional information (RAI) on September 17, 2020 (Reference 4). The RAI provides a 30-day response period.

Entergy's RAI response is included in the attached enclosure. The responses do not impact the no significant hazards consideration provided in the original amendment request (Reference 1).

No new regulatory commitments are included in this submittal.

In accordance with 10 CFR 50.91, Entergy is notifying the State of Arkansas of Entergy's RAI response by transmitting a copy of this letter and enclosure 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.

2CAN092002 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 22, 2020.

Respectfully, ORIGINAL SIGNED BY RON GASTON Ron Gaston RWG/dbb

Enclosure:

Response to Second Request for Additional Information Related to License Amendment Request Associated with Technical Specification Deletions, Additions, and Relocations Attachments to

Enclosure:

1. Technical Specification Page Markup

2. Retyped Technical Specification Page

References:

1. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "License Amendment Request related to Technical Specification Deletions, Additions, and Relocations," Arkansas Nuclear One, Unit 2 (2CAN121901) (ML19350B324), dated December 16, 2019.

2. NRC email to Entergy, "ANO-2 Final RAI RE: License Amendment Request Concerning Proposed Technical Specification Additions, Deletions, and Relocations (EPID L-2019-LLA-0284)," (2CNA062001)

(ML20154K762), dated June 1, 2020.

3. Entergy letter to NRC, "Response to Request for Additional Information Related to License Amendment Request Associated with Technical Specification Deletions, Additions, and Relocations," (2CAN062001)

(ML20169A558), dated June 17, 2020.

4. NRC email to Entergy, "ANO-2 Final RAI #2 RE: License Amendment Request Concerning Proposed Technical Specification Additions, Deletions, and Relocations (EPID L-2019-LLA-0284)," (2CNA092001)

(ML20262H075), dated September 17, 2020.

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

Enclosure 2CAN092002 Response to Second Request for Additional Information Related to License Amendment Request Associated with Technical Specification Deletions, Additions, and Relocations

2CAN092002 Enclosure Page 1 of 3 RESPONSE TO SECOND REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST ASSOCIATED WITH TECHNICAL SPECIFICATION DELETIONS, ADDITIONS, AND RELOCATIONS By letter dated December 16, 2019 (Reference 1), as supplemented by letter dated June 17, 2020 (Reference 3), Entergy Operations, Inc. (Entergy), requested NRC approval of a proposed change to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TSs) to enhance consistency with NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," Revision 4. During the course of review, the NRC determined additional information was required to complete the review process.

The NRC notified Entergy of the request for additional information (RAI) on September 17, 2020 (Reference 4). The RAI provides a 30-day response period.

Each question associated with the subject RAI is repeated below followed immediately by Entergy's response to the specific question.

Background from NRC RAI

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.

2CAN092002 Enclosure Page 2 of 3 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.

Entergy Response The adoption of the Explosive Gas and Storage Tank Radioactivity Monitoring Program (EGSTRMP) is intended to be based on the current ANO-2 license basis as stated in the excerpt from the TS 3.11.2 Bases shown above. Therefore, Reference 19 of the December 12, 2019 LAR (Reference 1) should be stated as follows:

19. NRC Branch Technical Position ETSB 11-5, Revision 0, "Postulated Radioactive Release due to Waste Gas System Leak or Failure," (ML052350105), July 1981.

This reference can result in some confusion since Revision 0 of ETSB 11-5 is contained with Revision 2 of NUREG-0800, "Standard Review Plan" (same ADAMS Accession number ML052350105). Entergy's response to RAI-ARECB-2 below is intended to alleviate this potential.

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.

Entergy Response The above excerpted statement from proposed TS 6.5.8 is modified as follows to state the specific version of ETSB 11-5:

The gaseous radioactivity quantities shall be determined following the methodology contained in Revision 2 of NUREG-0800, "Standard Review Plan," Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure," Revision 0, July 1981.

A revised markup and retyped version of the affected TS page is included in Attachments 1 and 2 of this enclosure, respectively.

2CAN092002 Enclosure Page 3 of 3 REFERENCES

1. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "License Amendment Request related to Technical Specification Deletions, Additions, and Relocations," Arkansas Nuclear One, Unit 2 (2CAN121901)

(ML19350B324), dated December 16, 2019.

2. NRC email to Entergy, "ANO-2 Final RAI RE: License Amendment Request Concerning Proposed Technical Specification Additions, Deletions, and Relocations (EPID L-2019-LLA-0284)," (2CNA062001) (ML20154K762), dated June 1, 2020.

3. Entergy letter to NRC, "Response to Request for Additional Information Related to License Amendment Request Associated with Technical Specification Deletions, Additions, and Relocations," (2CAN062001) (ML20169A558), dated June 17, 2020.

4. NRC email to Entergy, "ANO-2 Final RAI #2 RE: License Amendment Request Concerning Proposed Technical Specification Additions, Deletions, and Relocations (EPID L-2019-LLA-0284)," (2CNA092001) (ML20262H075), dated September 17, 2020.

Enclosure, Attachment 1 2CAN092002 Technical Specification Page Markup (1 page)

ADMINISTRATIVE CONTROLS 6.5.7 Reactor Coolant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendation of Regulatory Position C.4.b of Regulatory Guide 1.14, Revision 1, August 1975. The volumetric examination per Regulatory Position C.4.b.1 will be performed on approximately 10-year intervals.

6.5.8 DELETEDExplosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Decay Tanks, the quantity of radioactivity contained in the Waste Gas Decay Tanks, and the quantity of radioactivity contained in unprotected temporary outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology contained in Revision 2 of NUREG-0800, "Standard Review Plan," Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure," Revision 0, July 1981. The liquid radwaste quantities shall be determined in accordance with the ODCM.

The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Decay Tanks and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion),

b. A surveillance program to ensure that the quantity of radioactivity contained in each Waste Gas Decay Tank is less than the amount that would result in a whole body exposure of 0.5 rem to any individual in an unrestricted area, in the event of an uncontrolled release of the tanks' contents, and

c. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

ARKANSAS - UNIT 2 6-7 Amendment No. 255,262,291,305,

Enclosure, Attachment 2 2CAN092002 Retyped Technical Specification Page (1 page)

ADMINISTRATIVE CONTROLS 6.5.7 Reactor Coolant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendation of Regulatory Position C.4.b of Regulatory Guide 1.14, Revision 1, August 1975. The volumetric examination per Regulatory Position C.4.b.1 will be performed on approximately 10-year intervals.

6.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Decay Tanks, the quantity of radioactivity contained in the Waste Gas Decay Tanks, and the quantity of radioactivity contained in unprotected temporary outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology contained in Revision 2 of NUREG-0800, "Standard Review Plan," Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure," Revision 0, July 1981. The liquid radwaste quantities shall be determined in accordance with the ODCM.

The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Decay Tanks and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion),

b. A surveillance program to ensure that the quantity of radioactivity contained in each Waste Gas Decay Tank is less than the amount that would result in a whole body exposure of 0.5 rem to any individual in an unrestricted area, in the event of an uncontrolled release of the tanks' contents, and

c. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

ARKANSAS - UNIT 2 6-7 Amendment No. 255,262,291,305,