1CAN121802, Supplement to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)

Supplement to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)

ML18346A539
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/11/2018
From:	Richard Anderson Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN121802
Download: ML18346A539 (11)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Richard L. Anderson ANO Site Vice President 10 CFR 50.90 1CAN121802 December 11, 2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Supplement to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)

Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

Dear Sir or Madam:

By letter dated March 12, 2018 (Reference 1), as supplemented by letter dated April 26, 2018 (Reference 2), Entergy Operations, Inc. (Entergy), requested NRC approval of a proposed change to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TSs). The proposed amendment would modify ANO-1 TSs by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, Risk-Informed Technical Specification Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies, by adopting Technical Specification Task Force (TSTF)-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5.

By email dated September 19, 2018 (Reference 3), the NRC informed Entergy that additional information was needed to support the Staffs continued review of the application. Entergy responded with the requested information in letter dated October 17, 2018 (Reference 4).

Three of the Entergy responses included in the Reference 4 letter involved activities which are necessary to complete prior to TSTF-425 implementation. These activities are part of the ongoing ANO-1 probabilistic risk assessment (PRA) model update from the current Revision 5 to Revision 6. Because the PRA model revision may not be complete prior to potential NRC approval of TSTF-425 for ANO-1, Entergy is proposing that a condition be added to the ANO-1 Operating License (OL) which will prohibit modifying current surveillance frequencies in accordance with TSTF-425 until the required changes have been incorporated into the PRA model.

1CAN121802 Page 2 of 3 The list of activities yet to be completed and the proposed condition to the ANO-1 OL are discussed in the attached enclosure. No new regulatory commitments are included in this amendment request.

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.

If there are any questions or if additional information is needed, please contact Stephenie Pyle at 479-858-4704.

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

Executed on December 11, 2018.

Sincerely, ORIGINAL SIGNED BY RICHARD L. ANDERSON RLA/dbb

Enclosure:

Supplemental Information - Adoption of TSTF-425

REFERENCES:

1. Entergy Letter dated March 12, 2018, Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425), Arkansas Nuclear One, Unit 1 (1CAN031801) (ML18071A319)

2. Entergy letter dated April 26, 2018, Supplemental Information Supporting the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425), Arkansas Nuclear One, Unit 1, (1CAN041805)

(ML18117A493)

3. NRC email dated September 19, 2018, Final RAI RE: License Amendment Request to Adopt TSTF-425, Revision 3 (EPID L-2018-LLA-0063) (1CNA091801) (ML18263A302)

4. Entergy letter dated October 17, 2018, Response to Request for Additional Information Related to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425), Arkansas Nuclear One, Unit 1, (1CAN101801) (ML18290B060)

1CAN121802 Page 3 of 3 cc: Mr. Kriss Kennedy Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Thomas Wengert MS O-08B1A One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Enclosure to 1CAN121802 Supplemental Information Adoption of TSTF-425

Enclosure to 1CAN121802 Page 1 of 3 SUPPLEMENTAL INFORMATION ADOPTION OF TSTF-425 By letter dated March 12, 2018 (Reference 1), as supplemented by letter dated April 26, 2018 (Reference 2), Entergy Operations, Inc. (Entergy), requested NRC approval of a proposed change to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TSs). The proposed amendment would modify ANO-1 TSs by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, Risk-Informed Technical Specification Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies, by adopting Technical Specification Task Force (TSTF)-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5.

By email dated September 19, 2018 (Reference 3), the NRC informed Entergy that additional information was needed to support the Staffs continued review of the application. Entergy responded with the requested information in letter dated October 17, 2018 (Reference 4).

Three of the Entergy responses included in the Reference 4 letter involved activities which are necessary to complete prior to TSTF-425 implementation. These activities are part of the ongoing ANO-1 probabilistic risk assessment (PRA) model update from the current Revision 5 to Revision 6. Because the PRA model revision may not be complete prior to potential NRC approval of TSTF-425 for ANO-1, Entergy proposes that a condition be added to the ANO-1 Operating License (OL) which prohibits modifying current surveillance frequencies in accordance with TSTF-425 until the required changes have been incorporated into the PRA model. Until the proposed OL condition is met, relocated surveillance frequencies will remain equivalent to the frequencies which existed at the time of relocation from the TSs.

The following are excerpts from the aforementioned Reference 4 Entergy request for additional information (RAI) response related to activities that have not yet been completed:

Table 1 Associated RAI Question Applicable Response Excerpt The update to the model of record (MOR) for internal flooding is pending completion of the update to the internal events probabilistic risk assessment (PRA) model update which is expected fourth quarter 2018. As with the internal flooding PRA-RAI-01a model that was reviewed for the peer review, a comprehensive review of post-initiator human failure events (HFEs) for impact of flooding events will be performed for the model update. Any HFEs potentially affected by internal flooding events will be appropriately addressed in the PRA logic.

Enclosure to 1CAN121802 Page 2 of 3 Associated RAI Question Applicable Response Excerpt Although it is concluded that the use of higher seed values would have minimal or no impact on the overall internal flooding results, a tracking item (WT-WTHQN-2018-0229 CA-18) has PRA-RAI-01.c.iii been entered into the corrective action tracking system to ensure that the internal flooding PRA updates are completed before the models are used for STI extensions.

During the TSTF-425 implementation process, candidate STI PRA-RAI-01.d.i changes will be reviewed against the relevant sources of uncertainty identified for the ANO-1 PRA MOR. Those sources (also applies to of uncertainty determined to have the potential to challenge the PRA-RAI-01.d.iv) acceptance criteria for the STI change will be identified as key, and sensitivity studies performed in accordance with NEI 04-10.

In light of the above, Entergy proposes an OL condition similar to that proposed by the DC Cook Nuclear Facility associated with that facilities adoption of TSTF-425 (Reference 5):

The licensee shall implement the items listed in Table 2 of the enclosure to Entergy letter 1CAN121802, dated December 11, 2018, prior to implementation of the Surveillance Frequency Control Program.

The following Table 2 items summarize those activities described in Table 1 above that must be completed in order to comply with the proposed OL condition:

Table 2 A comprehensive review of post-initiator human failure events (HFEs) for impact of flooding events will be performed for the PRA Revision 6 model update. Any HFEs potentially affected by internal flooding events will be appropriately addressed in the PRA logic.

The internal flooding update supporting Revision 6 of the ANO-1 PRA model shall be completed.

Candidate Surveillance Testing Interval (STI) changes will be reviewed against the relevant sources of uncertainty identified for the ANO-1 PRA Revision 6 model update.

Those sources of uncertainty determined to have the potential to challenge the acceptance criteria for the STI change will be identified as key, and sensitivity studies performed in accordance with NEI 04-10.

In addition to the above, the response to PRA-RAI-01.d.i and PRA-RAI-01.d.ii included in the Reference 4 Entergy letter made reference to NUREG 1855, Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decision Making, but did not state which revision of the NUREG was being employed in the maintenance of the ANO-1 PRA model. The subject RAI response was with reference to NUREG 1855, Revision 1.

Enclosure to 1CAN121802 Page 3 of 3 of this enclosure provides a markup of the current ANO-1 OL, containing the proposed condition. Attachment 2 of this enclosure provides the re-typed version of the affected OL page.

REFERENCES:

1. Entergy Letter dated March 12, 2018, Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425), Arkansas Nuclear One, Unit 1 (1CAN031801) (ML18071A319)

2. Entergy letter dated April 26, 2018, Supplemental Information Supporting the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425), Arkansas Nuclear One, Unit 1, (1CAN041805) (ML18117A493)

3. NRC email dated September 19, 2018, Final RAI RE: License Amendment Request to Adopt TSTF-425, Revision 3 (EPID L-2018-LLA-0063) (1CNA091801) (ML18263A302)

4. Entergy letter dated October 17, 2018, Response to Request for Additional Information Related to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425), Arkansas Nuclear One, Unit 1, (1CAN101801)

(ML18290B060)

5. Indiana Michigan Power letter dated September 9, 2016, Follow-Up Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5B, Donald C. Cook Nuclear Plant Unit 1 and Unit 2 (AEP-NRC-2016-69) (ML16258A145)

ATTACHMENTS:

1. Proposed Operating License Changes (markup)

2. Revised Operating License Page

ENCLOSURE ATTACHMENT 1 to 1CAN121802 PROPOSED OPERATING LICENSE CHANGES (MARK-UP)

EOI shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The EOI CSP was approved by License Amendment No. 244 as supplemented by changes approved by License Amendment Nos. 247, 251, and 255.

(5) Implementation of the Improved Technical Specifications (ITS)

The licensee is authorized to relocate certain Technical Specification requirements previously included in Appendix A to licensee controlled documents, as described in Table R, Relocated Specifications, and Table LA, Removal of Details, attached to the Safety Evaluation for Amendment No. 215. These requirements shall be relocated to the appropriate documents as part of the implementation of the ITS.

The schedule for performing Surveillance Requirements (SRs) that are new or revised in Amendment No. 215 shall be as follows:

1. For SRs that are new in this amendment, the first performance shall be due at the end of the first surveillance interval, which begins on the date of implementation of this amendment.

2. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval shall begin upon completion of the first surveillance performed after implementation of this amendment.

3. For SRs that existed prior to this amendment that contained modified acceptance criteria, the performance shall be due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

4. For SRs that existed prior to this amendment whose interval of performance are being extended, the first extended surveillance interval shall begin upon completion of the last surveillance performed prior to the implementation of this amendment.

(6) Surveillance Frequency Control ProgramDeleted The licensee shall implement the items listed in Table 2 of the enclosure to Entergy letter 1CAN121802, dated December 11, 2018, prior to implementation of the Surveillance Frequency Control Program.

(7) Deleted Renewed License No. DPR-51 Amendment No. 215,244,247,251,255,

ENCLOSURE ATTACHMENT 2 to 1CAN121802 REVISED OPERATING LICENSE PAGE

EOI shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The EOI CSP was approved by License Amendment No. 244 as supplemented by changes approved by License Amendment Nos. 247, 251, and 255.

(5) Implementation of the Improved Technical Specifications (ITS)

The licensee is authorized to relocate certain Technical Specification requirements previously included in Appendix A to licensee controlled documents, as described in Table R, Relocated Specifications, and Table LA, Removal of Details, attached to the Safety Evaluation for Amendment No. 215. These requirements shall be relocated to the appropriate documents as part of the implementation of the ITS.

The schedule for performing Surveillance Requirements (SRs) that are new or revised in Amendment No. 215 shall be as follows:

1. For SRs that are new in this amendment, the first performance shall be due at the end of the first surveillance interval, which begins on the date of implementation of this amendment.

2. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval shall begin upon completion of the first surveillance performed after implementation of this amendment.

3. For SRs that existed prior to this amendment that contained modified acceptance criteria, the performance shall be due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

4. For SRs that existed prior to this amendment whose interval of performance are being extended, the first extended surveillance interval shall begin upon completion of the last surveillance performed prior to the implementation of this amendment.

(6) Surveillance Frequency Control Program The licensee shall implement the items listed in Table 2 of the enclosure to Entergy letter 1CAN121802, dated December 11, 2018, prior to implementation of the Surveillance Frequency Control Program.

(7) Deleted Renewed License No. DPR-51 Amendment No. 215,244,247,251,255,