ML062910327: Difference between revisions
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| issue date = 03/09/2007 | | issue date = 03/09/2007 | ||
| title = Issuance of Amendment Nos. 229 and 271 Technical Specifications, Emergency Cooling Pond Inspection and Inventory Requirements (TAC Nos. MC8768 and MC8769) | | title = Issuance of Amendment Nos. 229 and 271 Technical Specifications, Emergency Cooling Pond Inspection and Inventory Requirements (TAC Nos. MC8768 and MC8769) | ||
| author name = Saba F | | author name = Saba F | ||
| author affiliation = NRC/NRR/ADRO/DORL/LPLIV | | author affiliation = NRC/NRR/ADRO/DORL/LPLIV | ||
| addressee name = Mitchell T | | addressee name = Mitchell T | ||
| addressee affiliation = Entergy Operations, Inc | | addressee affiliation = Entergy Operations, Inc | ||
| docket = 05000313, 05000368 | | docket = 05000313, 05000368 | ||
| license number = DPR-051, NPF-006 | | license number = DPR-051, NPF-006 | ||
| contact person = Saba F | | contact person = Saba F, NRR/DORL/LPL4, 301-415-1447 | ||
| case reference number = TAC MC8768, TAC MC8769 | | case reference number = TAC MC8768, TAC MC8769 | ||
| package number = ML062910326 | | package number = ML062910326 | ||
Line 31: | Line 31: | ||
==Enclosures:== | ==Enclosures:== | ||
: 1. Amendment No. 229 to DPR-51 2. Amendment No. 271 to NPF-6 | : 1. Amendment No. 229 to DPR-51 2. Amendment No. 271 to NPF-6 | ||
: 3. Safety Evaluationcc w/encls: See next page T. Mitchell-2-A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will beincluded in the Commission's next biweekly Federal Register notice.Sincerely,/RA/Farideh E. Saba, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-313 and 50-368 | : 3. Safety Evaluationcc w/encls: See next page T. Mitchell-2-A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will beincluded in the Commission's next biweekly Federal Register notice.Sincerely,/RA/Farideh E. Saba, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-313 and 50-368 | ||
==Enclosures:== | ==Enclosures:== | ||
: 1. Amendment No. 229 to DPR-51 2. Amendment No. 271 to NPF-6 | : 1. Amendment No. 229 to DPR-51 2. Amendment No. 271 to NPF-6 | ||
: 3. Safety EvaluationDISTRIBUTION | : 3. Safety EvaluationDISTRIBUTION | ||
:PUBLIC LPLIV Reading RidsNrrDorlLpl4 RidsNrrPMFSaba RidsNrrLALFeizollahi RidsOgcRp RidsAcrsAcnwMailCenter GHill RidsNrrDirsItsb SSamaddar, NRR RidsRgn4MailCenter RidsNrrDorlPackage: ML062910326TSs: ML070680249Accession No.: ML062910327* safety evaluation input dated February 23, 2007OFFICENRR/LPL4/PMNRR/LPL4/LAEGCB*ITSB/BCOGC - NLONRR/LPL4/BCNAMEFSabaLFeizollahiSSamaddarTKobetzPMouldingDTerao DATE2/27/072/27/072/23/073/7/073/6/073/8/07OFFICIAL RECORD COPY ENTERGY OPERATIONS, INC.DOCKET NO. 50-313ARKANSAS NUCLEAR ONE, UNIT NO. 1AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 229Renewed License No. DPR-51 1.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Entergy Operations, Inc. (the licensee), datedOctober 25, 2005, as supplemented by letter dated March 20, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this license amendment will not be inimical to the commondefense and security or to the health and safety of the public; and E.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and Paragraph 2.c.(2) of Renewed Facility Operating License No. DPR-51.3.The license amendment is effective as of its date of issuance and shall be implementedwithin 60 days from the date of issuance.FOR THE NUCLEAR REGULATORYCOMMISSION/RA/David Terao, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation | :PUBLIC LPLIV Reading RidsNrrDorlLpl4 RidsNrrPMFSaba RidsNrrLALFeizollahi RidsOgcRp RidsAcrsAcnwMailCenter GHill RidsNrrDirsItsb SSamaddar, NRR RidsRgn4MailCenter RidsNrrDorlPackage: ML062910326TSs: ML070680249Accession No.: ML062910327* safety evaluation input dated February 23, 2007OFFICENRR/LPL4/PMNRR/LPL4/LAEGCB*ITSB/BCOGC - NLONRR/LPL4/BCNAMEFSabaLFeizollahiSSamaddarTKobetzPMouldingDTerao DATE2/27/072/27/072/23/073/7/073/6/073/8/07OFFICIAL RECORD COPY ENTERGY OPERATIONS, INC.DOCKET NO. 50-313ARKANSAS NUCLEAR ONE, UNIT NO. 1AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 229Renewed License No. DPR-51 1.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Entergy Operations, Inc. (the licensee), datedOctober 25, 2005, as supplemented by letter dated March 20, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this license amendment will not be inimical to the commondefense and security or to the health and safety of the public; and E.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and Paragraph 2.c.(2) of Renewed Facility Operating License No. DPR-51.3.The license amendment is effective as of its date of issuance and shall be implementedwithin 60 days from the date of issuance.FOR THE NUCLEAR REGULATORYCOMMISSION/RA/David Terao, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation |
Revision as of 11:11, 13 July 2019
ML062910327 | |
Person / Time | |
---|---|
Site: | Arkansas Nuclear ![]() |
Issue date: | 03/09/2007 |
From: | Farideh Saba NRC/NRR/ADRO/DORL/LPLIV |
To: | Mitchell T Entergy Operations |
Saba F, NRR/DORL/LPL4, 301-415-1447 | |
Shared Package | |
ML062910326 | List: |
References | |
TAC MC8768, TAC MC8769 | |
Download: ML062910327 (18) | |
Text
March 9, 2007Mr. Timothy G. MitchellVice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S. R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTSRE: EMERGENCY COOLING POND INSPECTION AND INVENTORY REQUIREMENTS (TAC NOS. MC8768 AND MC8769)
Dear Mr. Mitchell:
The Nuclear Regulatory Commission has issued the enclosed Amendment No. 229 to RenewedFacility Operating License No. DPR-51 and Amendment No. 271 to Renewed Facility Operating License No. NPF-6 for Arkansas Nuclear One, Units 1 and 2 (ANO-1 and 2), respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to yourapplication dated October 25, 2005, as supplemented by letter dated March 20, 2006. The amendments revise the Limiting Conditions for Operation 3.7.8 for ANO-1 and 3.7.4.1 forANO-2, and their associated actions and surveillance requirements (SRs). The proposed changes address inventory and inspection requirements associated with the emergency cooling pond (ECP), which is a common cooling water source for both units during conditions that may render the normal cooling water source (Dardanelle Reservoir) unavailable. The proposed changes are a result of the need to add TS SRs for routine inspection of the ECP structure for degradation and provide an appropriate action should any degradation be discovered. The changes also include a reconciliation of the difference between the existing TS-indicated ECP level of 5 feet and the required ECP level, in order to maintain a volume of water equal to 70 acre-feet in the ECP.
T. Mitchell-2-A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will beincluded in the Commission's next biweekly Federal Register notice.Sincerely,/RA/Farideh E. Saba, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-313 and 50-368
Enclosures:
- 3. Safety Evaluationcc w/encls: See next page T. Mitchell-2-A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will beincluded in the Commission's next biweekly Federal Register notice.Sincerely,/RA/Farideh E. Saba, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-313 and 50-368
Enclosures:
- 3. Safety EvaluationDISTRIBUTION
- PUBLIC LPLIV Reading RidsNrrDorlLpl4 RidsNrrPMFSaba RidsNrrLALFeizollahi RidsOgcRp RidsAcrsAcnwMailCenter GHill RidsNrrDirsItsb SSamaddar, NRR RidsRgn4MailCenter RidsNrrDorlPackage: ML062910326TSs: ML070680249Accession No.: ML062910327* safety evaluation input dated February 23, 2007OFFICENRR/LPL4/PMNRR/LPL4/LAEGCB*ITSB/BCOGC - NLONRR/LPL4/BCNAMEFSabaLFeizollahiSSamaddarTKobetzPMouldingDTerao DATE2/27/072/27/072/23/073/7/073/6/073/8/07OFFICIAL RECORD COPY ENTERGY OPERATIONS, INC.DOCKET NO. 50-313ARKANSAS NUCLEAR ONE, UNIT NO. 1AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 229Renewed License No. DPR-51 1.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Entergy Operations, Inc. (the licensee), datedOctober 25, 2005, as supplemented by letter dated March 20, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this license amendment will not be inimical to the commondefense and security or to the health and safety of the public; and E.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and Paragraph 2.c.(2) of Renewed Facility Operating License No. DPR-51.3.The license amendment is effective as of its date of issuance and shall be implementedwithin 60 days from the date of issuance.FOR THE NUCLEAR REGULATORYCOMMISSION/RA/David Terao, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and the Technical SpecificationsDate of Issuance: March 9, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 229RENEWED FACILITY OPERATING LICENSE NO. DPR-51DOCKET NO. 50-313Replace the following pages of the Renewed Facility Operating License No. DPR-51 andAppendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Operating LicenseREMOVEINSERT - 3 -Technical SpecificationsREMOVEINSERT3.7.8-13.7.8-13.7.8-23.7.8-2 ENTERGY OPERATIONS, INC.DOCKET NO. 50-368ARKANSAS NUCLEAR ONE, UNIT NO. 2AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 271Renewed License No. NPF-61.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Entergy Operations, Inc. (the licensee), datedOctober 25, 2005, as supplemented by letter dated March 20, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this license amendment will not be inimical to the commondefense and security or to the health and safety of the public; and E.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-6.3.The license amendment is effective as of its date of issuance and shall be implementedwithin 60 days from the date of issuance.FOR THE NUCLEAR REGULATORYCOMMISSION/RA/David Terao, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and the Technical SpecificationsDate of Issuance: March 9, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 271RENEWED FACILITY OPERATING LICENSE NO. NPF-6DOCKET NO. 50-368Replace the following pages of the Renewed Facility Operating License No. NPF-6 andAppendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Operating LicenseREMOVEINSERT 33Technical SpecificationsREMOVEINSERT3/4 7-163/4 7-16 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NOS. 229 AND 271 TORENEWED FACILITY OPERATING LICENSE NOS. DPR-51 AND NPF-6ENTERGY OPERATIONS, INC.ARKANSAS NUCLEAR ONE, UNIT NOS. 1 AND 2DOCKET NOS. 50-313 AND 50-36
81.0INTRODUCTION
By letter dated October 25, 2005 (Reference 1), Entergy Operations, Inc. (Entergy, thelicensee), requested an amendment to the Technical Specifications (TSs) for Arkansas NuclearOne, Unit 1 (ANO-1) and Unit 2 (ANO-2). The proposed change modifies inventory and inspection requirements associated with the Emergency Cooling Pond (ECP), which is a common cooling water source for both ANO units. Limiting Conditions for Operation (LCO) 3.7.8 (for ANO-1) and 3.7.4.1 (for ANO-2), "Emergency Cooling Pond," and their associated Actions and Surveillance Requirements (SRs) are affected by the proposed change.
Subsequently, the licensee submitted a supplement to the License Amendment Request (LAR) by letter dated March 20, 2006 (Reference 2), that modified the wording of TS SRs 3.7.8.1 and 4.7.4.1.a (for ANO-1 and ANO-2, respectively) to enhance clarity per request of the Nuclear Regulatory Commission (NRC) staff. The March 20, 2006, letter did not change the NRC staff's original no significant hazards consideration determination as published in the Federal Registeron October 24, 2006 (71 FR 62309). The Dardanelle Reservoir provides the primary heat sink during normal plant operation, whilethe ECP is the Seismic Category I backup source of cooling water for plant safe shutdown, if necessary, under normal or accident conditions. The ECP serves as a heat sink for simultaneously shutting down both ANO-1 and ANO-2 in the unlikely event of a loss of the Dardanelle Reservoir water inventory. Natural surface drainage (drainage area, 225 acres) is used as makeup for evaporation losses. In addition, the pond minimum water level can be maintained by supplying makeup water from either the Russellville water supply line to the plant site, or from Dardanelle Reservoir using the service water pumps. A spillway is provided for the overflow of excess water. The minimum design storage volume of the ECP for emergency cooling needs is 70 acre-feet.Unexpected degradation of the ECP was observed during the early part of 2005. Thisdegradation resulted in detailed follow-up inspections, evaluations, and repairs of the ECP to ensure its continued compliance with station design and license requirements. During this evaluation, Entergy determined that the ECP-indicated level that corresponds to a contained volume of 70 acre-feet is 5.05 feet. Although the ECP water level has been historically maintained at 5.5 feet, the current TS SR of verifying the indicated ECP level (every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)to be greater than or equal to 5 feet was not conservative. In accordance with NRC Administrative Letter 98-10, Entergy put in place administrative controls to ensure that the ECP is maintained at greater than or equal to 5.2 feet indicated level. This LAR is intended primarily to reconcile this difference for both ANO units. The proposed change will relocate ECP-indicated level requirements to the TS Bases. Therequired ECP volume of 70 acre-feet will remain in the TS. Presently the action to perform an engineering evaluation of any degradation of the ECP structure is found in the TS Bases. This requirement will be relocated as a new TS Action. Concurrently, the details of the ECP structural inspections will be relocated from the TS to the TS Bases. The above changes affect the following TS requirements:ANO-1ANO-2LCO 3.7.8, Action A (new)LCO 3.7.4.1.aLCO 3.7.8, Action BLCO 3.7.4.1, Actions "a" and "b" SR 3.7.8.1SR 4.7.4.1 SR 3.7.8.3SR 4.7.4.1.a SR 3.7.8.4SR 4.7.4.1.cSR 4.7.4.1.d*(* The licensee mistyped this Section to read SR 4.7.4.1.b in its October 25, 2006 letter,submittal, Attachment 1, "Analysis of Proposed Technical Specification Change," Page 1)Corresponding changes are made to the TS Bases also, and are included in the submittal asinformation only.The minimum design storage volume for the ECP is 70 acre-feet, and is a requirement for theECP to remain operable. Degradation of the ECP may also compromise its operability.
Changes to the TS requirements being proposed in the LAR for ANO-1 and ANO-2, as stated above, provide SRs and required actions in connection with operability of the ECP pertaining to maintaining minimum storage volume and to degradation of the ECP. Therefore, changes to these TS requirements must be evaluated to ensure that the ECP will continue to comply with its design and license requirements.
2.0REGULATORY EVALUATION
The ECP is the safety-related backup ultimate heat sink for ANO-1 and ANO-2. This feature ispart of the original plant design and licensing basis. General Design Criterion 44, "Cooling water," of Appendix A, "General Design Criteria (GDC),"to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR), "Licensing of Productionand Utilization Facilities," requires, in part, that suitable redundancy in features be provided for the cooling water system to ensure that its safety function can be accomplished. GDC 2, "Design bases for protection against natural phenomena," requires, in part, that structures, systems, and components important to safety be designed to withstand the effects of natural phenomena without loss of capability to perform their safety functions. Regulatory Guide (RG) 1.27, "Ultimate Heat Sink for Nuclear Power Plants," Revision 1, describes a basisacceptable to the NRC staff that may be used to implement GDC 44 and 2 with regard to a particular feature of the cooling water system, namely the ultimate heat sink.Pursuant to Section 50.90 of 10 CFR, Entergy has requested amendments to the TS for ANO-1 and 2. The amendments affected the TS LCOs 3.7.8 and 3.7.4.1, and their associated actions and SRs. The LAR is required to be evaluated for no significant hazards consideration by the licensee in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c). The TS changes proposed by Entergy in this LAR are required to be evaluated to confirmcompliance with the above regulatory requirements.
3.0TECHNICAL EVALUATION
3.1Summary of Entergy's Technical Analysis Entergy has provided technical analysis of the TS changes for both ANO-1 and ANO-2 togetherto address the essential elements of the changes as follows:a.Relocation of ECP-indicated level requirements from the TS to the TS Bases
The licensee stated that the minimum design basis volume requirement of the ECP is 70 acre-feet. Both ANO units' TSs require inspection and sounding of the ECP on an annual basis. The information gathered through these surveillances provides a means of determining the minimum indicated level at which the ECP must be maintained to ensure that a 70 acre-feet volume is available at all times during operation in Modes 1, 2, 3, and 4. Because the required volume is designated in the TS, and because the corresponding indicated level may change throughout plant life, indicated level is being proposed to be relocated to the TS Bases. In doing so, sufficient regulatory control is maintained within the TS to ensure design-basis requirements will continue to be met while relieving the licensee of the unnecessary burden of requesting a change to the TS as indicated level changes.b.Relocation of details of structural inspections from the TS to the TS Bases The licensee stated that relocation of SR details to the TS Bases is consistent with thephilosophy of the Integrated Technical Specifications (ITS) for all plant types.c.Relocation of action to perform engineering evaluation for observed degradation from theTS Bases to the TS The licensee stated that the action to be taken when ECP degradation is discovered pursuantto the TS SRs, or by other inspection, consists of an engineering evaluation intended to determine continued ECP operability, and it is inappropriate for such required actions to be located in the TS Bases. The TS Bases, as approved by the NRC, did not include a completion time for this engineering evaluation. Therefore, the licensee proposed a 7-day completion time.
The licensee believes that 7 days is reasonable based on the low likelihood that a loss of the Dardanelle Reservoir would occur in any 7-day period. Even if a loss of the Dardanelle Reservoir were to occur, it is unlikely that the noted ECP degradation would result in the unavailability of the ECP as a cooling water source through the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an accidentwhen decay heat loads are elevated.The licensee proposed to update the relevant sections of the TS Bases for both units tocorrespond to the proposed changes to the TS, and included them in the LAR for information only. The licensee finally concluded that the proposed TS changes acted to correct current TS deficiencies while reducing the burden on the licensee with regard to submitting future TS changes each time the ECP-indicated level is adjusted to correspond with the TS volume limit of 70 acre-feet. The licensee believes that the changes have no significant impact on plant operation, nuclear safety, or the health and safety of the public.3.2Summary of Entergy's Regulatory Analysis The licensee stated that the proposed changes did not require any exemptions or relief fromregulatory requirements, other than the TSs, and did not affect conformance with any GDC other than as described in the safety analysis reports (SARs).Entergy also evaluated whether or not a significant hazards consideration was involved with theproposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," and concluded that the proposed amendment presented no significant hazards consideration.3.3Staff Technical Evaluation The objective of the staff review was to determine if the changes to the TSs of ANO-1 andANO-2 proposed by Entergy in its LAR will have any adverse impact on the ECP, or on monitoring of the ECP, to ensure its availability to perform its intended design function.The staff reviewed the licensee's technical analysis of the three primary elements of theproposed change, described in Section 3.3 of this document, as follows: a.Relocation of ECP-indicated level requirements from the TS to the TS Bases The NRC staff reviewed the licensee's proposal for relocation of the ECP-indicated levelrequirements from the TS to the TS Bases. The design-basis requirement of the ECP is to maintain minimum 70 acre-feet of water in the ECP. This design-basis requirement of maintaining the minimum ECP volume will still remain in the TS. The indicated ECP level is an operator aid for routine verification that the required ECP inventory is maintained. The TSs will require inspection and sounding of the ECP on an annual basis for determining the minimum indicated level at which the ECP must be maintained to ensure a 70 acre-feet volume is available at all times during operation Modes 1, 2, 3, and 4. The required indicated level to maintain the minimum ECP volume may change throughout the plant's life, and may require updating. Therefore, relocating the minimum indicated ECP level to the TS Bases will help avoid unnecessary TS revision while still providing the necessary assurance that the design basis is met. Based on the above, the NRC staff concludes that relocation of ECP-indicated water level from the TS to the TS Bases is acceptable. b.Relocation of details of structural inspections from the TS to the TS BasesThe NRC staff reviewed the licensee's proposal to relocate details of structural inspections fromthe TS to the TS Bases. The procedures for actual inspection of the ECP are more detailed than what is currently described in the TS, and relocating excessive detail from the SR section of the TS to the TS Bases does not reduce the level of inspection required with regard to ECP operability verifications. The SR will still contain the requirement for visual inspection of the ECP to verify conformance with design requirements, and it will thus provide the necessary assurance that the ECP's safety function can be performed. Therefore, the staff believes that relocating the details of structural inspection currently in the TS to the TS Bases is acceptable.c.Relocation of action to perform engineering evaluation for observed degradation from theTS Bases to the TS The NRC staff reviewed the licensee's proposal to relocate the requirement to performengineering evaluation for observed degradation of the ECP from the TS Bases to the TS. The staff agrees that the TS is the appropriate location to contain required actions for failed surveillances. The staff considers that this change will remove a deficiency with the current TS.
The licensee has also proposed to require that the engineering evaluation be performed within 7 days. Currently, the TS Bases do not have a completion time for this action. The staff believes that the proposed 7-day completion time is reasonable based on the low likelihood that a loss of the Dardanelle Reservoir would occur in any 7-day period. Even if a loss of the Dardanelle Reservoir were to occur, the staff considers it unlikely that the ECP degradation discovered would result in the unavailability of the ECP as a cooling water source through the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an accident when decay heat loads are elevated. Based on the above, the staff concludes that relocation of the requirement to perform an evaluation for observed degradation of the ECP with a 7-day completion time is acceptable.
The NRC staff's review of the changes to the TS sections with respect to each unit are provided in the following paragraphs.ANO-1LCO 3.7.8 Action A (new): This new Action is added to require evaluation to determine within7 days that the ECP remains acceptable for continued operation subsequent to observed degradation pursuant to SR 3.7.8.4 or by other inspection. The NRC staff considers this acceptable for the reasons explained in Section 3.3(c) above.LCO 3.7.8 Action B: This is an editorial change to include newly added Action A in the LCOCondition. The NRC staff considers this acceptable because it clarifies conditions to be met for the ECP to remain operable.SR 3.7.8.1:The requirement to verify that the water level is 5 feet has been removed from theSR. The revised requirement verifies that the indicated water level is greater than or equal to that required for ECP volume of 70 acre-feet. As explained in Section 3.3(a) above, The NRC staff considers this acceptable.SR 3.7.8.3: Currently, this section requires annual verification that the contained water volume of ECP is greater than or equal to 70 acre-feet at water level of 5 feet. The method ofsoundings to be used for verification was specified in the TS Bases. This verification provided assurance that measurement of water level of 5 feet will guarantee 70 acre-feet of water in the ECP. This Section is being revised to perform sounding to verify that the contained water volume of ECP is greater than or equal to 70 acre-feet and that the minimum indicated water level needed to ensure a volume of 70 acre-feet is maintained. The value of the indicated water level has been moved to the TS Bases. The NRC staff considers this acceptable because the SR will ensure that the minimum water volume of the ECP is maintained, and the indicated water level to maintain minimum water volume will be verified or updated, as required, without requiring revisions to the TS.SR 3.7.8.4:This section has been revised to remove details of inspection of the ECP to beperformed annually. The revised text requires performing annual visual inspection of the ECP to verify conformance with design requirements. The NRC staff considers this acceptable because details of inspection need not to be included in the SR as explained in Section 3.3(b) above.ANO-2LCO 3.7.4.1.a: The reference to indicated water level of 5 feet to define operability of the ECPhas been removed from this section. The NRC staff considers this acceptable because contained water volume, rather than water level, is the design requirement for the ECP. In addition, the abbreviation (ECP) is added in reference to the emergency to the emergency cooling pond. This change is only editorial, and the staff finds it acceptable.LCO 3.7.4.1 Actions "a" and "b": The Action (a) statement has been revised to clarifyoperability parameters of the ECP, and include reference to the new Action (b) to define operability. This change is clarifies the operability definition and accommodates the new Action (b) in the text. Therefore, the change is acceptable. The Action (b) statement has been added to require performing an evaluation within 7 days if degradation is noted pursuant to SR 4.7.4.1.d or by other inspection. The NRC staff considers this acceptable for the reasons explained in Section 3.3(c) above.SR 4.7.4.1:ECP is abbreviated for emergency cooling pond. This is change is only editorial,and the NRC staff finds it acceptable.SR 4.7.4.1.a: The requirement to verify that the water level is 5 feet has been removed from theSR. The revised requirement verifies that the indicated water level is greater than or equal to that required for ECP volume of 70 acre-feet. For the reasons explained in Section 3.3(a) above, the NRC staff considers this acceptable.SR 4.7.4.1.c: This section has been revised to annually verify by soundings that the containedwater volume of the ECP is greater than or equal to 70 acre-feet, and the minimum indicated water level needed to ensure a volume of 70 acre-feet is maintained. The current reference to verify the water level of 5 feet has been removed. The NRC staff considers this acceptable for the reasons explained in Section 3.3(a) above.SR 4.7.4.1.d: This section has been revised to remove details of inspection of the ECP to be performed annually. The revised text requires performing annual visual inspection of the ECPto verify conformance with design requirements. The NRC staff considers this acceptable because details of inspection need not to be included in the SR as explained in (b) above.3.4Staff Regulatory Evaluation Entergy submitted the LAR pursuant to 10 CFR 50.90 to revise sections of the TS pertaining tothe ECP. The ECP is the original design and licensing basis feature for both ANO-1 and ANO-2. ANO has adopted RG 1.27, Revision 1. RG 1.27 is referenced in the SAR for both units, and is acceptable to the NRC for complying with the regulatory requirements of GDC 44 and 2 of 10 CFR Part 50, Appendix A, as described in Section 2.0 of this document. The changes proposed in the LAR do not involve any changes to the design basis of the ECP.
Therefore, the proposed changes do not have any adverse impact on continued compliance of the ECP with RG 1.27.
4.0STATE CONSULTATION
In accordance with the Commission's regulations, the Arkansas State official was notified of theproposed issuance of the amendment. The State official had no comments.
5.0ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed findingthat the amendments involve no significant hazards consideration, and there has been no public comment on such finding published on October 24, 2006 (71 FR 62309). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) thereis 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 issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
7.0REFERENCES
1.Entergy letter to NRC dated October 25, 2005, "License Amendment Request,Emergency Cooling Pond Inspection and Inventory Requirements, Arkansas Nuclear One - Unit 1 and Unit 2," Agencywide Document Access and Management System (ADAMS) Accession No. ML053050422.2.Entergy Letter to NRC dated March 20, 2006, "License Amendment Request,Supplemental to Emergency Cooling Pond Inspection and Inventory Requirements, Arkansas Nuclear One - Unit 1 and Unit 2," ADAMS Accession No. ML060890042.Principal Contributor: Samir Chakrabarti Date: March 9, 2007 February 2007Arkansas Nuclear One cc:Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995General Manager PlantOperations Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802Director, Nuclear Safety AssuranceEntergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802Manager, LicensingEntergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802Director, Nuclear Safety & LicensingEntergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298Section Chief, Division of HealthRadiation Control Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867Section Chief, Division of HealthEmergency Management Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867Senior Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 310 London, AR 72847Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064County Judge of Pope County 100 W. Main Street Russellville, AR 72801Vice President, Operations SupportEntergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995