2CAN030801, Response to Request for Additional Information, License Amendment Request to Revise Technical Specification 6.6.5, Core Operating Limits Report

Response to Request for Additional Information, License Amendment Request to Revise Technical Specification 6.6.5, Core Operating Limits Report

ML080710408
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/11/2008
From:	James D Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN030801
Download: ML080710408 (6)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4619 Dale E. James Manager, Licensing Arkansas Nuclear One 2CAN030801 March 11, 2008 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Request for Additional Information License Amendment Request to Revise Technical Specification 6.6.5, Core Operating Limits Report Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCE:

1. Entergy Letter to NRC dated July 31, 2007 License Amendment Request to Revise Technical Specification 6.6.5, Core Operating Limits Report

Dear Sir or Madam:

By letter dated July 31, 2007 (Reference 1), Entergy Operations, Inc. (Entergy) proposed to revise the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specification 6.6.5 to add new analytical methods to support the implementation of Next Generation Fuel (NGF).

During the review of the Reference 1 submittal, a question was raised from the Reactor Systems Branch. This question (Request for Additional Information (RAI)) was informally transmitted to Entergy on February 7, 2008. Several discussions with the NRC have taken place since transmittal of the RAI. The RAI and Entergys response to the RAI is included in .

There are no technical changes proposed. The conclusions of the original no significant hazards consideration included in Reference 1 are not affected by any information contained in this supplemental letter.

This letter contains one new commitment. This commitment is identified in Attachment 2.

2CAN030801 Page 2 of 2 If you have any questions or require additional information, please contact Bob Clark at (479) 858 4663.

Sincerely, DEJ/rwc Attachments: 1. Response to Request for Additional Information Related to the COLR Listing of Methodologies

2. List of Regulatory Commitments cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U.S. Nuclear Regulatory Commission Attn: Mr. Alan B. Wang MS O-7 D1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health & Human Services P.O. Box 1437 Slot H-30 Little Rock, AR 72203-1437

ATTACHMENT 1 2CAN030801 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE COLR LISTING OF METHODOLOGIES to 2CAN030801 Page 1 of 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE COLR LISTING OF METHODOLOGIES NRC Question:

Under TAC MD6220, the proposed TS 6.6.5 COLR, addition of new methods to COLR, in the July 31, 2007 submittal, there are five new methodologies to be added to the COLR TS to support the coming cycle-specific operating parameters. However, many methods are proposed to support the same parameter. We would like the licensee to clarify that: (1) the proposed changes are applicable to the coming cycle; and (2) how to apply the methods proposed to support same parameter such as 3 methods for MTC, 3 methods for Azimuthal Power Tilt, 4 methods for ASI, 3 methods for Linear Heat Rate, and 3 methods for DNBR.

Response

In the upcoming Cycle 20, Entergy intends to implement the Next Generation Fuel (NGF) design. The proposed changes to TS 6.6.5 are needed to support the implementation of NGF.

In response to a portion of the RAI regarding an explanation of the connection or relationship between the referenced approved methodologies, the relationship was addressed satisfactorily during conference calls between the NRC staff reviewer, ANO-2 Project Manager (PM), Westinghouse and Entergy personnel.

Based upon the understanding of the relationship between the large number (10) of core operating limit report (COLR) references that presently exist in TS 6.6.5 and the additional five (5) references being proposed, the NRC Staff requested Entergy to commit to evaluate the COLR references and propose a TS change within the next 12 months to minimize the number of references. As an example, there are four COLR references that have a relationship with the COLR parameter limit of Shutdown Margin (TS 3.1.1.1.and 3.1.1.2), in that, three of the references describe current methodology being used. However, the other reference associated with Shutdown Margin has been superseded by more recently implemented methodology and thus, can be evaluated for deletion.

Therefore, to satisfy this condition, Entergy commits to evaluate other similar plants Technical Specification (TS) methodology references that reflect NRC approved methods used in establishing the COLR parameter limits. Based on that evaluation, Entergy will propose a change to TS 6.6.5, to minimize the number of references consistent with the guidance provided in Generic Letter 88-16, Removal of Cycle-Specific Parameter Limits from Technical Specifications. This proposed TS change will be submitted within 12 months following NRC issuance of the approved amendment for the current requested change to TS 6.6.5. This regulatory commitment is contained in Attachment 2.

ATTACHMENT 2 2CAN030801 LIST OF REGULATORY COMMITMENTS to 2CAN030801 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMMITMENT COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE Entergy commits to evaluate other similar plants Technical Specification (TS)

X Within 12 methodology references that reflect NRC months approved methods used in establishing the following NRC COLR parameter limits. Based on that issuance of the evaluation, Entergy will propose a change to approved TS 6.6.5, to minimize the number of amendment for references consistent with the guidance the current provided in Generic Letter 88-16, Removal of requested Cycle-Specific Parameter Limits from change to TS Technical Specifications. This proposed TS 6.6.5.

change will be submitted within 12 months following NRC issuance of the approved amendment for the current requested change to TS 6.6.5.