0CAN069601, Application for Amends to Licenses DPR-51 & NPF-6,allowing Reactor Containment Bldg Equipment Hatch Doors to Remain Open During Fuel Handling & Core Alterations

Application for Amends to Licenses DPR-51 & NPF-6,allowing Reactor Containment Bldg Equipment Hatch Doors to Remain Open During Fuel Handling & Core Alterations

ML20113D127
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/28/1996
From:	Yelverton J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20113D131	List: 0CAN069601, Application for Amends to Licenses DPR-51 & NPF-6,allowing Reactor Containment Bldg Equipment Hatch Doors to Remain Open During Fuel Handling & Core Alterations ML20113D132
References
0CAN069601, CAN69601, NUDOCS 9607030028
Download: ML20113D127 (7)

Text

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-:-:- ENTERGY cmie,sy oge,.iiom.. imc.

"=33 Rrxi!iilt ta 72301 Tc150 E 8 5000 l June 28,1996 l OCAN069601 l

l U. S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137 l Washington, DC 20555 l

Subject:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Technical Specification Change Request Concerning Open l

Containment Equipment Hatch During Core Alterations Gentlemen:

Attached for your review and approval are technical specification changes allowing the Arkansas Nuclear One (ANO) Unit I and Unit 2 reactor containment building equipment hatch doors to remain open during fuel handling and core alterations. Entergy Operations has determined that approval of this change will save approximately $800,000 per refueling outage. This results in a savings of over $21 million for the remaining life of the ANO units, and therefore, is considered to be a cost beneficial licensing action. This change also allows quick and efficient evacuation of containment should a fuel handling accident occur. This prompt containment evacuation results in reduced dose to the workers. This chang has been submitted to the NRC by the Nuclear Energy Institute Technical Specification Task Force as a generic change to the Standard Technical Specifications.

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations are included in the attached submittal.

Entergy Operations requests that the effective date for this change be within 30 days of issuance. Although this request is neither exigent nor emergency, your prompt review is requested prior to the next ANO-1 refueling outage (IR13) which is currently scheduled to begin September 17,1996.

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9607030028 960628 PDR ADOCK 05000313 P PDR ND t

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U. S. NRC

. June 28,1996 0CAN069601 Page 2 Very truly yours, b

Attachments To the best of my knowledge and belief, the statements contained in this submittal are true.

SUBSCRIBED AND SWORN TO before me, a Notary Public in and for h County and the State of Arkansas, this <3i day of Oua ,1996.V

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Chm 1R -bo .,ur.L Notary Public() V' Nggumam My Commission Expires l{'3 ~ M uso-wii.e.som ec: Mr. Leonard J. Callan 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 Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard Bevill Arkansas Department of Health Acting Director, Division of Radiation Control and Emergency Management 4815 West Markham Street Little Rock, AR 72205

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I ATTACHAENT )

to OCAN069601 PROPOSED TECHNICAL SPECIFICATION AND RESPECTIVE SAFETY ANALYSES IN THE MATTER OF AMENDING LICENSE NOs. DPR-51 and NPF-6 ENTERGY OPERATIONS,INC.

ARKANSAS NUCLEAR ONE, UNITS ONE & TWO DOCKET NOs.30-313 and 50-368

Attachment to

. OCAN069601 l Page1of4 l

DESCRIPTION OF PROPOSED CHANGES The proposed changes to the ANO-1 and ANO-2 Technical Specifications include the following:

• Specification 3.8.6 for ANO-1 including associated bases has been revised to allow the reactor building equipment hatch door to remain open during fuel handling.

• Specification 3.9.4.a for ANO-2 including associated bases has also been revised to allow l the containment equipment hatch door to remain open during core alterations.

BACKGROUND l

ANO-1 and ANO-2 Technical Specifications 3.8.6 and 3.9.4.a, respectively, require the containment equipment hatch door be closed and secured with a minimum of four bolts during core alterations and handling or movement ofirradiated fuel within the reactor containment building. The purpose of this requirement is to mitigate the consequences of a fuel handling accident. Entergy Operations has previously submitted (for both of the ANO units) and l gained approval of a new fuel handling accident analysis (for ANO-2) which assumes that the containment is open for the duration of the accident. Approval for ANO-1 is pending the NRC's review of additional information submitted by Entergy Operations on June 10,1996 (ICAN069606). This same approach is now being applied to the contaimnent equipment hatch door.

During shutdown when the decay heat removal or shutdown cooling systems for ANO-1 and ANO-2, respectively, are in use with fuel in the core, site procedures require the containment equipment hatch door have the capability to be closed within the estimated time to steam release should a loss of shutdown cooling or decay heat removal occur. These procedures establish containment closure controls, give guidance to the person responsible for establishing containment closure, provide a checklist of equipment and materials that are required to be maintained available for use in establishing containment closure, and provide a list of protrusions through the equipment hatch along with a description and the name and phone number of the responsible person or organization.

As a routine activity during outages, drills are performed to verify the ability to establish equipment hatch closure. During recent refueling outages, drills have been performed in which closure times for the containment equipment hatch door were approximately five minutes, but in all cases, were less than 15 minutes for each of the ANO units.

With the containment equipment hatch door open during fuel handling and core alterations, equipment, trash, laundry, etc. that cannot safely be removed through the personnel airlock can be easily and efliciently moved in and out of the reactor containment building. This makes it easier to maintain a clean, safe working environment. With the equipment hatch closed during fuel handling and core alterations, trash accumulates in the reactor containment

Attachment to '

OCAN069601 Page 2 of 4 building. This requires a fire watch to be posted and thus, increases radiation exposure, I manpower requirements, and cost. l Also, the need to remove the equipment, trash, laundry, etc. buildup from the reactor containment building is required to be balanced against the need to bring in equipment during the outage. This normally causes equipment removal to delay the final closure of the containment equipment hatch door prior to heatup. If the containment equipment hatch door could be Icfl open during fuel handling and core alterations, this extra time would allow equipment to be removed from the reactor containment building off of critical path and in a more schedule efficient manner.

The impact of having the equipment hatch door closed during fuel movement causes an increase of approximately 1,000 entries per day, on the average, through the personnel hatch.

This change in access points increases the transit time for individuah by approximately 30 minutes per round trip entry. If one outage person-hour is worth $58 (normalized value), then the cost of the equipment hatch door being closed for one day is equal to $29,870 per day.

This equates to $238,960 for an 8 day fuel handling period.

During a typical refueling outage, work scope and relt.ted e itcal path sequencing is logically rehted to the availability of the equipment hatch door being open. A review of refueling outage schedules reveal approximately 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> of potential critical path savings had the equipment hatch door been allowed to remain open during fuc! handling. The cost of critical path time is approximately $404,000 per day (excluding replacement power cost). Based on the 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />, a savings of $555,500 would be realized per refueling outage should the equipment hatch door be allowed to remain open during fuel handling.

The combination of the savings gained from leaving the equipment hatch door open during the j entire refueling outage would be $238,960 from decreased entries through the personnel hatch  !

and $555,500 from decreased critical path time. This results in a combined savings of l approximately $794,460 per refueling outage. I DISCUSSION OF CHANGE This proposed change to technical specifications would allow the containment equipment  ;

hatch door to be open during fuel movement and core alterations. The purpose of the current requirement to have the containment equipment hatch door closed during core uterations and fuel movement is to prevent the escape of radioactive material in the event of a %el handling accident. The current fuel handling accident analyses show that it is not necessg to have containment closure in order to show acceptable site boundary doses following a fuel handling l accident. The ANO-1 and the ANO-2 fhel handling accident analyses assumed that the conti.inment equipment hatch doors were open at the time of the accident. In support of a l

requen to allow the containment personnel airlock doors to remain open during core alteratie.3, this analysis was submitted on May 19,1995 (0CAN059503), as supplemented by j letter dated July 21,1995 (OCAN079509). This request was approved by the Staff on

[ Attachm:nt to' ,

, OCAN069601 Pay 3 of4 September 28,1995 (2CNA099506), as Amendment No.166 to the ANO-2 Technical Specifications. Additional information was recently submitted on June 10, 1996 (ICAN069606), in order to support the ANO-1 fuel assembly drop analysis. Please note that the attached proposed ANO-1 Technical Specifications incorporate the previous request for j allowing the reactor building personnel airlock doors te 3 main open during fuel handling and i a*e & pendent upon approval of the previously requested change.

There are a large number of people in containment during refueling outages including during  ;

fuel movement and core alterations. Should a fuel handing accident occur, the containment  ;

cou'i be evacuated more expeditiously with the equipment hatch door open than with it closed, thus enhancing personnel safety. This would reduce dose to the workers in the event of an accident while maintaining acceptable 10CFR Part 100 doses to the public. Also, in the  ;

emt of a fuel handing accident inside containment, the equipment hatch door will be closed i following an evacuation of containment.

Due to significant physical plant design differences between ANO and other nuclear units, the ANO units are able to close tbdr containment equipment hatch door easily and efficiently. At both of the ANO units, it hadn a previously demonstrated that the equipment hatch door can be closed within approximately 15 minutes. Therefore, the justification provided for the ,

previously approved technical specification change for ANO-2 to allow the containment personnel airlock doors to remain open during core alterations would also be applicable to the ANO containment equipment hatch doors. j An individual will be designated to monitor the condition of the open equipment hatch door l during core alterations and will assure closure of the equipment hatch door following containment evacuation. The assurance that the open equipment hatch door will remain ,

capable of prompt closure will be administratively controlled in site procedures. Any items l passing through the door that could obstruct closure of the door will hr.ve either quick disconnect capability or will be readily removable.

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION An evaluation of the proposed change has been performed in accordance with 10CFR50.91(a)(1) regarding no significant hazwds considerations using the standards in 10CFR50.92(c). A discussion of these standaru as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant lacrease in the Probability or Consequences of an Accident Previously Evaluated.

The proposed change would allow the containment equipment hatch door to remain open during fuel movement and core alterations. This door is normally closed during this time period in order to prevent the escape of radioactive material in the event of a fuel handling accident. This door is not an initiator of any accident. The probability of a fuel handling 1

a

Attachment to l OCAFD69601 l Page 4 of 4 i accident is unaffected by the position of the containment equipment hatch door. The current fuel handling accident analysis, which has been approved by the Staff for ANO-2 and I submitted for ANO-1, calculates maximum offsite doses to be well within the limits of 10CFR Part 100. The current fuel handling accident analysis results in maximum offsite doses of 63.6 and 41.8 Rem to the thyroid and 0.902 and 0.598 Rem to the whole body (sum of beta and gamma) for ANO-1 and ANO-2, respectively. This analysis assumes the entire release from the damaged fuel is allowed to migrate to the site boundary unobstructed. Therefore, allowing the equipment hatch doors to remain open results in no change in consequences.

Also, the calculated doses during a fuel handling accident would be considerably larger than the actual doses since the calculation does not incorporate the closing of the equipment hatch door following evacuation of containment. The proposed change would significantly reduce the dose to workers in the containment in the event of a fuel handling accident by expediting the containment evacuation process. Therefore, this change does nel involve a significant increase in the probability or consequences of any accident previously evaluated.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind cf Accident from any Previously Evaluated.

The proposed change does not involve the addition or modification of any plant equipment.

Also, the proposed change would not alter the design, configuration, or method of operation of the plant beyond the standard functional capabilities of the equipment. Therefore, this change does npf create nt'e possibility of a new or different kind of accident from any previoasly evaluated.

Criterion 3 - Does Not Involve a Significant Reduction in the Margin of Safety.

This proposed change does not have the potential for an increased dose at the site boundary due to a fuel handling accident. The margin of safety as defined by 10CFR Part 100 has not j been significantly reduced. Closing the equipment hatch door following an evacucion of containment further reduces the offsite doses in the event of a fuel handling accident and provides additional margin to the calculated offsite doses. Therefore, this change does not involve a significant reduction in the margin of safety.

Based upon the reasoning presented above and the previous discussion of the amendment ,

request, Entergy Operations proposes that the requested change does aplinvolve a significant l hazards consideration. ,

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