Text

License Amendment Request, Revise Technical Specifications to Adopt TSTF-569, Revision of Response Time Testing Definitions
	ML20268B898
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/24/2020
From:	Gaston R; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	2CAN092003
	Download: ML20268B898 (17)
	v • d • e

10 CFR 50.90 2CAN092003 September 24, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

License Amendment Request Revise Technical Specifications to Adopt TSTF-569, "Revision of Response Time Testing Definitions" Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 As required by 10 CFR 50.90, Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit 2 (ANO-2).

Entergy requests adoption of TSTF-569, "Revise Response Time Testing Definition," which is an approved change to the Improved Standard Technical Specifications (ISTS), into the ANO-2 TS. The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF)

Response Time and Reactor Trip System (RTS) Response Time.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides existing TS Bases pages marked to show the proposed changes for information only. provides retyped (revised) TS pages.

Entergy requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within six months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.

This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91, Entergy is notifying the State of Arkansas of this amendment request by transmitting a copy of this letter and enclosure to the designated State Official.

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing

2CAN092003 Page 2 of 2 Should you have any questions or require additional information, please contact Riley Keele, Manager, Regulatory Assurance, Arkansas Nuclear One, at 479-858-7826.

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

Executed on September 24, 2020.

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

Enclosure:

Evaluation of the Proposed Change Attachments to

Enclosure:

1.

Technical Specification Page Markups

2.

Technical Specification Bases Page Markup (for Information Only)

3.

Retyped Technical Specification Pages cc:

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

Enclosure 2CAN092003 Evaluation of the Proposed Change

2CAN092003 Enclosure Page 1 of 5 EVALUATION OF THE PROPOSED CHANGE

1.0 DESCRIPTION

Entergy Operations, Inc. (Entergy) requests adoption of TSTF-569, "Revise Response Time Testing Definition," which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS). The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Entergy has reviewed the safety evaluation for TSTF-569 provided to the Technical Specifications Task Force (TSTF) in a letter dated August 14, 2019. This included a review of the NRC staffs Safety Evaluation (SE), as well as the information provided in TSTF-569. As described herein, Entergy has concluded that the justifications presented in TSTF-569 and the SE prepared by the NRC staff are applicable to ANO-2 and justify this amendment for the incorporation of the changes to the ANO-2 TSs.

2.2 Variations Entergy is proposing the following variations from the TS changes described in the TSTF-569 or the applicable parts of the NRC staffs SE.

1.

The ANO-2 TSs contain requirements that differ from the improved standard TSs (ISTS) of NUREG 1432, "Standard Technical Specifications for Combustion Engineering Plants,"

Revision 4, on which TSTF-569 was based, such as definition titles and wording, but these differences do not affect the applicability of the TSTF-569 justification.

The ANO-2 TS use the definition title, "Reactor Trip System Response Time" instead of the Combustion Engineering ISTS definition title, "Reactor Protection System (RPS) Response Time."

The ANO-2 definition of Reactor Trip System Response Time has differences in word order, stating "until electrical power is interrupted to the CEA drive mechanism,"

instead of the ISTS wording of "until electrical power to the CEAs drive mechanism is interrupted."

These differences are administrative and do not affect the applicability of TSTF-569 to the ANO-2 TSs.

2.

The ANO-2 TS change resulted in the Liquid Radwaste Treatment System TS Definition 1.28, being forced off TS Page 1-5. This definition is moved to TS Page 1-6.

This is reflected in the mark ups and clean retyped TS pages. This is an administrative change and does not affect the applicability of TSTF-569 to the ANO-2 TSs.

2CAN092003 Enclosure Page 2 of 5

3.

The traveler and NRC SE discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC). ANO-2 was not licensed to the 10 CFR 50, Appendix A, GDC. ANO-2 was originally designed to comply with the 70 "Proposed General Design Criteria for Nuclear Power Plant Construction Permits," published in July 1967. However, the ANO-2 Safety Analysis Report (SAR) provides a comparison with the Atomic Energy Commission (AEC) GDC published as Appendix A to 10 CFR 50 in 1971. The applicable AEC GDC were compared to 10 CFR 50, Appendix A, GDC as discussed below.

TSTF-569 references 10 CFR 50, Appendix A, GDC 13, "Instrumentation and Control,"

which states:

Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems.

Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

GDC 13 is discussed in ANO-2 SAR Section 3.1.2, "Protection by Multiple Fission Product Barriers," which states, in part:

Instrumentation is provided to monitor and maintain significant process variables which can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Controls are provided for the purpose of maintaining these variables within the limits prescribed for safe operation.

TSTF-569 references 10 CFR 50, Appendix A, GDC 21, "Protection System Reliability and Testability," which states:

The protection system shall be designed for high functional reliability and inservice testability commensurate with the safety functions to be performed. Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

GDC 21 is discussed in ANO-2 SAR Section 3.1.3, "Protection and Reactivity Control Systems," which states, in part:

The protection system is designed to comply with the requirements of IEEE 279-1971.

No single failure will result in the loss of the protection function. The protection channels are independent, e.g. with respect to piping, wire routing, mounting and supply of power.

This independence permits testing and the removal from service of any component or channel without loss of the protection function.

2CAN092003 Enclosure Page 3 of 5 Following implementation of the proposed change, ANO-2 will remain in compliance with AEC GDC as discussed in the SAR. Therefore, this difference does not alter the conclusion that the proposed change is applicable to ANO-2.

3.0 REGULATORY EVALUATION

3.1 No Significant Hazards Consideration Analysis Entergy Operations, Inc. (Entergy) requests adoption of TSTF-569, "Revise Response Time Testing Definition," which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TSs). The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time.

Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the TS Definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The requirement for the instrumentation to actuate within the response time assumed in the accident analysis is unaffected.

The response time associated with the RTS and ESF instrumentation is not an initiator of any accident. Therefore, the proposed change has no significant effect on the probability of any accident previously evaluated.

The affected RTS and ESF instrumentation are assumed to actuate their respective components within the required response time to mitigate accidents previously evaluated.

Revising the TS definition for RTS and ESF instrumentation response times to allow an NRC-approved methodology for verifying response time for some components does not alter the surveillance requirements that verify the RTS and ESF instrumentation response times are within the required limits. As such, the TS will continue to assure that the RTS and ESF instrumentation actuate their associated components within the specified response time to accomplish the required safety functions assumed in the accident analyses. Therefore, the assumptions used in any accidents previously evaluated are unchanged and there is no significant increase in the consequences.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2CAN092003 Enclosure Page 4 of 5

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises the TS Definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The proposed change does not alter any assumptions made in the safety analyses. The proposed change does not alter the limiting conditions for operation for the RTS or ESF instrumentation, nor does it change the Surveillance Requirement to verify the RTS and ESF instrumentation response times are within the required limits. As such, the proposed change does not alter the operability requirements for the RTS and ESF instrumentation, and therefore, does not introduce any new failure modes.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change revises the TS Definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change has no effect on the required RTS and ESF instrumentation response times or setpoints assumed in the safety analyses and the TS requirements to verify those response times and setpoints. The proposed change does not alter any Safety Limits or analytical limits in the safety analysis. The proposed change does not alter the TS operability requirements for the RTS and ESF instrumentation. The RTS and ESF instrumentation actuation of the required systems and components at the required setpoints and within the specified response times will continue to accomplish the design basis safety functions of the associated systems and components in the same manner as before. As such, the RTS and ESF instrumentation will continue to perform the required safety functions as assumed in the safety analyses for all previously evaluated accidents.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

2CAN092003 Enclosure Page 5 of 5

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Enclosure, Attachment 1 2CAN092003 Technical Specification Page Markups (3 Pages)

ARKANSAS - UNIT 2 1-5 Amendment No. 24,60,157,193,239, DEFINITIONS AXIAL SHAPE INDEX 1.22 The AXIAL SHAPE INDEX shall be the power generated in the lower half of the core less the power generated in the upper half of the core divided by the sum of these powers.

REACTOR TRIP SYSTEM RESPONSE TIME 1.23 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power is interrupted to the CEA drive mechanism. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

ENGINEERED SAFETY FEATURE RESPONSE TIME 1.24 The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

PHYSICS TESTS 1.25 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.59, or

3) otherwise approved by the Commission.

SOFTWARE 1.26 The digital computer SOFTWARE for the reactor protection system shall be the program codes including their associated data, documentation and procedures.

PLANAR RADIAL PEAKING FACTOR Fxy 1.27 The PLANAR RADIAL PEAKING FACTOR is the ratio of the peak to plane average power density of the individual fuel rods in a given horizontal plane, excluding the effects of azimuthal tilt.

ARKANSAS - UNIT 2 1-5 Amendment No. 24,60,157,193,239, LIQUID RADWASTE TREATMENT SYSTEM 1.28 A LIQUID RADWASTE TREATMENT SYSTEM is a system designed and installed to reduce radioactive liquid effluents from the unit. This is accomplished by providing for holdup, filtration, and/or demineralization of radioactive liquid effluents prior to their release to the environment.

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ARKANSAS - UNIT 2 1-6 Amendment No. 60,149,157,193,239, 255,305, DEFINITIONS LIQUID RADWASTE TREATMENT SYSTEM 1.28 A LIQUID RADWASTE TREATMENT SYSTEM is a system designed and installed to reduce radioactive liquid effluents from the unit. This is accomplished by providing for holdup, filtration, and/or demineralization of radioactive liquid effluents prior to their release to the environment.

MEMBER(S) OF THE PUBLIC 1.29 MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational or other purposes not associated with the plant.

PURGE - PURGING 1.30 PURGE or PURGING is the controlled process of discharging air or gas from a confinement to reduce airborne radioactive concentrations in such a manner that replacement air or gas is required to purify the confinement.

EXCLUSION AREA 1.31 The EXCLUSION AREA is that area surrounding ANO within a minimum radius of

.65 miles of the reactor buildings and controlled to the extent necessary by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials.

UNRESTRICTED AREA 1.32 An UNRESTRICTED AREA shall be any area at or beyond the exclusion area boundary.

CORE OPERATING LIMITS REPORT 1.33 The CORE OPERATING LIMITS REPORT is the ANO-2 specific document that provides core operating limits for the current operating reload cycle. These cycle-specific core operating limits shall be determined for each reload cycle in accordance with Technical Specification 6.6.5. Plant operation within these operating limits is addressed in individual specifications.

INSERVICE TESTING PROGRAM 1.34 The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

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Enclosure, Attachment 2 2CAN092003 Technical Specification Bases Page Markup (for Information Only)

(1 Page)

ARKANSAS - UNIT 2 B 3/4 3-1a Amendment No. 159,195,239 Issued by NRC Letter Dated June 18, 1998 Rev. 24,40,44,73, 3/4.3 INSTRUMENTATION BASES Table 4.3-2 requires the Automatic Actuation Logic channels for each of the associated ESFAS functional units to have a CHANNEL FUNCTIONAL TEST performed in accordance with the Surveillance Frequency Control Program. These testing requirements also apply to the six ESFAS Matrix Logic channels and the four ESFAS Initiation Logic channels. The ESFAS Matrix Logic channels are divided up for testing purposes like the RPS Matrix Logic channels.

The measurement of response time at the specified frequencies provides assurance that the protective and ESF action function associated with each channel is completed within the time limit assumed in the accident analyses.

No credit was taken in the analyses for those channels with response times indicated as not applicable.

Response time may be demonstrated by any series of sequential, overlapping or total channel test measurements, provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by 1) in place, onsite or offsite test measurements or 2) utilizing replacement sensors with certified response times or

3) utilizing allocated response time for selected sensors. Topical Report CE NPSD-1167-A, Elimination of Pressure Sensor Response Time Testing Requirements, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the Topical Report. The response time may be verified for components that replace the components that were previously evaluated in CE NPSD-1167-A provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, "Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing." Response time verification for sensor types must be demonstrated by test. The allocation of sensor response times must be verified prior to placing a new component in operation and re-verified after maintenance that may adversely affect the sensor response time.

Plant Protective System (PPS) logic is designed for operation as a 2-out-of-3 logic, although normally it is operated in a 2-out-of-4 mode.

The RPS Logic consists of everything downstream of the bistable relays and upstream of the Reactor Trip Circuit Breakers. The RPS Logic is divided into two parts, Matrix Logic, and Initiation Logic. Failures of individual bistables and their relays are considered measurement channel failures.

The ESFAS Logic consists of everything downstream of the bistable relays and upstream of the subgroup relays. The ESFAS Logic is divided into three parts, Matrix Logic, Initiation Logic, and Actuation Logic. Failures of individual bistables and their relays are considered measurement channel failures.

Matrix Logic refers to the matrix power supplies, trip channel bypass contacts, and interconnecting matrix wiring between bistable relay cards, up to, but not including the matrix relays. Matrix contacts on the bistable relay cards are excluded from the Matrix Logic definition since they are addressed as part of the measurement channel.

Enclosure, Attachment 3 2CAN092003 Retyped Technical Specification Pages (2 Pages)