ML23296A100

Entergy Presentation Slides for Pre-Submittal Meeting on 10/24/23, Mtc LAR

ML23296A100
Person / Time
Site:	Arkansas Nuclear, Waterford
Issue date:	10/24/2023
From:	Entergy Operations
To:	Lingham S NRC/NRR/DORL/LPL4
Wengert T
References
EPID L-2023-LRM-0081
Download: ML23296A100 (1)

Text

Arkansas Nuclear One Unit 2 Waterford 3 Pre-Submittal Meeting to Adopt Moderator Temperature Coefficient Tech Spec Change October 24, 2023

Agenda

• Background

• Current Requirements

• Proposed Changes

• Discussion of the Change

• Precedent

• Timeline for Submittal

• Open Discussion 2

Background

• Arkansas Nuclear One Unit 2 (ANO2) and Waterford 3 (WF3) have Technical Specifications (TS) based on NUREG-0212.

• The NUREG-0212 Technical Specifications provide more information than is generally contained in the Improved Standard Technical Specification (ISTS).

• The TS typically do not specify how a surveillance should be performed, only that a parameter should be within limits.

• The TS do not specify references to specific topical reports that are used.

• The proposed License Amendment Request (LAR) will more closely align the ANO2 and WF3 Moderator Temperature Coefficient (MTC) TSs with the structure in NUREG-1432.

3

Current Requirements - ANO2 ANO2 MTC Technical Specification is documented in TS 3.1.1.4

• The Limiting Condition for Operation (LCO) for ANO2 is similar to the ISTS in function with some minor wording differences.

• The current applicability includes a footnote (*) for Keff 1.0 in MODE 2.

• The current end state mode in the Action statement is referred to by name.

4

Current Requirements - ANO2 ANO2 MTC Technical Specification is documented in TS 3.1.1.4.

• The surveillance requirement (SR) states that MTC shall be confirmed by measurement.

• SR 4.1.1.4.2 specifies that the surveillance is performed prior to and above 5% rated thermal power (RTP).

5

Current Requirements - ANO2 ANO2 MTC Technical Specification is documented in TS 3.1.1.4.

• SR 4.1.1.4.1 and SR 4.1.1.4.2 are modified by notes that allow prediction to verify MTC in accordance with WCAP-16011-P-A.

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Current Requirements - WF3 WF3 MTC Technical Specification is documented in TS 3.1.1.3.

• The LCO for WF3 is similar to the ISTS in function with some minor wording differences.

• The current applicability includes a footnote (1) for Keff 1.0 in MODE 2.

• The current end state mode in the Action statement is referred to by name.

7

Current Requirements - WF3 WF3 MTC Technical Specification is documented in TS 3.1.1.3.

• The SR states that MTC shall be confirmed by measurement.

• SR 4.1.1.3.2 specifies that the surveillance is performed prior to 5% RTP, greater than 15%,

and at any power.

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Current Requirements - WF3 WF3 MTC Technical Specification is documented in TS 3.1.1.3.

• SR 4.1.1.3.1 and SR 4.1.1.3.2 are modified by notes that allow prediction to verify MTC in accordance with WCAP-16011-P-A.

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Proposed Changes ANO2 and WF3 will adopt the structure of the ISTS (ANO2 example is shown).

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Discussion of the Change

• Current SRs are structured using NUREG-0212. This structure specifies a specific surveillance procedure will be used to verify the MTC.

• Current SRs contain the word measured, which precludes using another procedure to verify that the surveillances are met.

• Revising the wording in SRs from measured to verified is consistent with the ISTS.

• Using the word verified will allow the use of other procedures to verify the surveillances are met.

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Discussion of the Change

• The industry has worked on several initiatives to reduce the number of times that MTC is measured in the plant.

• South Texas Project (STP) submitted a LAR in 2021 (ML21014A213) that was withdrawn (ML21237A056).

• The STP LAR provided a specific procedure that would be used to verify MTC.

• Entergy is not requesting approval of a new procedure that will be used to verify MTC.

• At this time, Entergy is not making any change to the procedure that is used to verify the MTC.

• Future changes to the surveillance procedures will be assessed in accordance with 10 CFR 50.59.

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Precedent NUREG-1432, Standard Technical Specifications for Combustion Engineering Plants.

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Timeline for Submittal

• Submittal to NRC - 1st quarter 2024

• Requesting normal NRC approval schedule 14

CLOSING REMARKS 15