0CAN089801, Revises 961219 Submittal to Incorporate New Control Room Duct Radiation Monitor.Util Requests That Effective Date for Change Be within 30 Days of NRC Approval

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Revises 961219 Submittal to Incorporate New Control Room Duct Radiation Monitor.Util Requests That Effective Date for Change Be within 30 Days of NRC Approval
ML20236Y591
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 08/06/1998
From: Hutchinson C
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236Y593 List:
References
0CAN089801, CAN89801, NUDOCS 9808120329
Download: ML20236Y591 (9)
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e Entergy Operations,Inc.

=Entergy =-

Tel 501858-4888 C. Randy Hutchinson he Preson August 6,1998 OCAN089801 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station OP1-17 Washington, DC 20555

Subject:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Revision to Proposed Technical Specification Change Concerning Control Room Ventilation Systems l Gentlemen:

By letter dated April 4,1995 (OCAN049501), Entergy Operations proposed Technical Specification (TS) changes revising those requirements associated with the Arkansas Nuclear One Unit 1 (ANO-1) and Arkansas Nuclear One Unit 2 (ANO-2) control room emergency ventilation systems. The changes to the ANO-1 TS were intended to clarify the common control room emergency habitability equipment requirements and make the requirements more consistent with those specified for ANO-2. One additional change to both the ANO-1 and ANO-2 requirements involved an extension to the allowed outage time for one inoperable train of the emergency air conditioning system from seven days to thirty days.

The April 4, 1995, submittal was superseded by letter dated December 19, 1996 (0CAN129603), in order to respond to reviewer comments. This December 19, 1996, submittal incorporated the testing methodology of ASTM D3803-1989 as the laboratory

testing standard for both units, and revised the proposed filter testing acceptance criteria in j accordance with the reviewer comments.

During the review of proposed TS changes concerning the ANO-2 main steam line isolation signal setpoint reduction, letter dated September 23,1997 (2CAN099703), the ability of the ANO-1 control room area monitor to meet the design requirements for actuating the control room emergency ventilation system was questioned. By [[letter::2CAN029807, Forwards Response to Telcon RAI Re TS Change Request, Reducing RCS Flow Requirements & Main Steam Isolation Signal Setpoints to Allow Up to 30% SG Tube Plugging.Proprietary Dose Evaluation,Encl.Proprietary Info Withheld|letter dated February 27, 1998]] (2CAN029'o07), Entergy Operations described a plant modification which installed a scintillation type radiation monitor in the ANO-1 control room normal air intake duct, and committed to revise our proposed control room ventilation TS change request to incorporate this new radiation monitor.

! ,sostao3av 98oe06 DR ADOCK o 33 Qi l

.. U. S. NRC August 6,1998 l OCAN089801 Page 2 l

This submittal is intended to revise our December 19,1996 submittal to incorporate the new l

ANO-1 control room duct radiation monitor. It also revises our submittal to incorporate an enhancement that has been determined to be necessary to successfully implement the proposed TS. This enhancement is the addition of an ANO-2 required action to give the operator guidance in the event the combination of one control room emergency air conditioning system l and one control room emergency ventilation system is inoperable. Due to the structure of the proposed ANO-1 TSs, this enhancement already existed in our previous submittals. This submittal also incorporates changes required due to the implementation of ANO-1 Amendment 192 and ANO-2 Amendment 191 (both issued on July 13,1998).

l The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that these changes are bounded by the i no significant hazards considerations evaluated in our December 19,1996, submittal.

Entergy Operations requests that the effective date for this change be within 30 days of NRC approval. Although this request is neither exigent nor emergency, your prompt review is requested.

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Very truly y rs, /// \

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

SUBSCRIBED AND SWORN TO before me, a Notary blic in and for 42fr>

l County and the State of Arkansas, this [dpf day of AM ,1998./

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LacJ2aama Motary fublic f i

My Commission Expires MM/[M l

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'. U. S. NRC August 6,1998 i l, OCAN089801 Page 3 l i

! cc: Mr. Ellis W. Merschoff Regional Administrator f

U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 l Arlington, TX 76011-8064  ;

i-NRC Senior Resident Inspector L Arkansas Nuclear One P.O. Box 310 i l London, AR 72847 Mr. William D. Reckley 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 l

Mr. David D. Snellings Director, Division ofRadiation Control and Emergency Management l Arkansas Department ofHealth

! 4815 West Markham Street i

Little Rock, AR 72205 l

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ATTACHMENT 1Q OCAN089801 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. 50-313 and 50-368 l

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( Att chment to 0CAN089801 Page1 of5 DESCRIPTION OF PROPOSED CHA~NGES The proposed control room ventilation system technical specifications (TSs) contained in the Arkansas Nuclear One letter dated December 19,1996 (0CAN129603) are revised to:

e Remove ANO-1 TS page 42a from the affected pages due to the incorporation of ANO-1 l Amendment 192, l

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  • Incorporate the Arkansas Nuclear One - Unit 1 (ANO-1) contrcl room normal ventilation intake duct monitor in the bases associated with the proposed ANO-1 TS 3.5.1.13, e Incorporate ANO-1 Amendment 192 which relocated information from ANO-1 TS page 45d2 to page 45dl, l

( e Clarify the proposed requirements of ANO-1 TS 3.9.1 and 3.9.2 by the addition of" train" in place of" system,"

e Remove ANO-1 TS page 72bl from the affected pages due to the incorporation of ANO-1 Amendment 192, l

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! e Clarify the proposed requirements of ANO-1 TS 4.10.2 by the addition of" train" in place of" system,"

e Reduce the level of detail proposed for Arkansas Nuclear One - Unit 2 (ANO-2) TS Table 3.3-6, Instrument 2.b, " Control Room Ventilation Radiation Monitors,"

  • Modify the proposed changes to ANO-2 TS Table 4.3-3, Instrument 2b to specify the I surveillance requirements for both control room ventilation intake duct monitors,
e. Incorporate an additional required action in ANO-2 TS 3.7.6.1 (Action C) to provide

! guidance in the event the combination of one control room emergency air conditioning system and one control room emergency ventilation system is inoperable, l

  • Incorporate ANO-2 Amendment 191 on affected page 3/4 7-18, e Incorporate ANO-2 Amendment 191 on affected par 3e B3/4 3-2, and

+ Incorporate the Arkansas Nuclear One - Unit 1 (ANO-1) control room normal ventilation intake duct monitor in the bases associated with the proposed ANO-2 TS Table 3.3-6 Instrument 2.b, TS Bases 3/4.3.3.1.

The proposed TS pages included in our December 19,1996, submittal have been reprintd in this submittal for completeness. These pages have been revised to incorporate the changes described above.

o Attachment to OCAN089801 Page 2 of 5 '

BACKGROUND During discussions with the staff on proposed ANO-2 changes, which were subsequently approved as Amendment 189, dated March 12,1998, the ability of the ANO-1 control room area monitor to meet its design requirements for actuating the control room emergency ventilation system was questioned. Given the location of the monitor and its setpoint, the control room operators could be exposed to a high thyroid dose (in excess of General Design Criteria 19 equivalent limits) before the monitor would actuate the control room emergency I

ventilation system. The area monitor effectively measured whole body doses, but did not compensate for the concentrating effects of iodine inhalation. Additional information describing a plant modification installing an ANO-1 control room normal ventilation intake duct radiation monitor was provided by Entergy Operations in a [[letter::2CAN029807, Forwards Response to Telcon RAI Re TS Change Request, Reducing RCS Flow Requirements & Main Steam Isolation Signal Setpoints to Allow Up to 30% SG Tube Plugging.Proprietary Dose Evaluation,Encl.Proprietary Info Withheld|letter dated February 27, 1998]] (2CAN029807).

l l The new ANO-1 duct monitor consists of a scintillation type detector, and an associated I preamplifier and rate meter with a sensitivity that is the same as the existing ANO-2 control room ventilation intake duct process monitor. The new duct monitor also will have the same s; 2 times background isolation setpoint requirements as that of the existing ANO-2 duct monitor.

All of the components installed by the modification were procured as nuclear qualified and mounted seismically with all seismic II/I issues addressed. The new duct monitor is also powered from a diesel backed safety grade (class 1E) power supply. These components are the same type of equipment that is installed in the ANO-2 control room normal air intake duct.

The existing ANO-1 control room area radiation monitor is not designed as a safety grade component and is powered from a non-class IE power supply. The new ANO-1 duct monitor .

improves on the current design by installing safety grade equipment that is powered from a i

diesel backed IE power supply. However, both the existing area monitor and the new duct l monitor will actuate the safety grade isolation relay via cables that are not class 1E consistent l with the current design. The new duct monitor simply taps into the existing non-class IE circuit from the control room area monitor circuit. Electrical isolation is provided between L the non-safety related detection circuit and the safety related components.

In the [[letter::2CAN029807, Forwards Response to Telcon RAI Re TS Change Request, Reducing RCS Flow Requirements & Main Steam Isolation Signal Setpoints to Allow Up to 30% SG Tube Plugging.Proprietary Dose Evaluation,Encl.Proprietary Info Withheld|letter dated February 27,1998]], Entergy Operations committed to submit an additional

modification to the proposed control room ventilation TS change request, letter dated December 19,1996 (0CAN12%03), to address the new ANO-1 normal ventilation intake duct radiation monitor. Entergy Operations will also administratively apply the same

! surveillance and operability requirements that currently exist for the ANO-2 duct monitor, to the ANO-1 duct monitor until the above referenced TS change requests are approved. In addition, Entergy Operations also requests the NRC to increase the priority on the staffs review of the above referenced TS changes for the common control room radiation detection, emergency filtration, and emergency air conditioning equipment. These changes were proposed to eliminate the differing requirements located in both units TS for the common control room equipment.

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4 Attachment to 0CAN089801 Page 3 of 5 )

i DISCUSSION OF CHANGE -

The pages contained in this submittal have been revised to reflect the incorporation of ANO-1 Amendment 192 (issued on July 13,1998) and ANO-2 Amendment 191 (issued on July 13, ,

1998). These Amendments relocated the requirements associated with the control room 1 ventilation chlorine detection system, seismic monitoririg instrumentation and turbine f overspeed from both ANO-1 and ANO-2 TS, and also relocated the requirements associated l

'with meteorological instrumentation from' the ANO-2 TS. The incorporation of these

amendments allows the removal of ANO-1 pages 42a and 72bl from the affected pages as no l changes are now necessary. The requirements for the control room radiation monitoring

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instruments have been renumbered from the proposed ANO-1 TS 3.5.1.17 to ANO-1 TS j l

3.5.1.13. ANO-1 Amendment 192 repositioned information from ANO-1 TS page 45d2 to )

I page 45d1 and deleted page 45d2. The requirements formerly shown on ANO-1 page 45d2 l are now shown on page 45dl, and the proposed Functional Unit 18 incorporating the control rcom radiation monitors has been revised as Functional Unit 14, due to the relocation of the seismic monitoring instrumentation.

In the December 19,1996 submittal, Entergy Operations proposed the new requirement, TS l 3.5.1.17, to explicitly require the operability of the radiation monitors. This new requirement

will now be numbered as TS 3.5.1.13. The bases information proposed for the new TS l- 3.5.1.13 has been revised to replace the reference to the ANO-1 area radiation monitor with a reference to the ANO-1 control room ventilation intake duct monitor. For consistency in terminology, the reference to the ANO-2 control room ventilation monitor has been replaced with a reference to the ANO-2 control room ventilation intake duct monitor. The current ANO-1 TSs require operability of the radiation monitors only by requiring that the control room ventilation dampers be capable ofisolating within 10 seconds after receipt of a high

[ radiation signal. The installation of the ANO-1 control room ventilation intake duct monitor j was found to be acceptable under the requirements of 10 CFR 50.59. Therefore, replacing the l- reference to the ANO-1 control room area radiation monitor in the bases with a reference to the ANO-1 control room ventilation process monitor has been determined to be administrative in nature and bounded by the determmation of no signi6 cant hazards consideration presented L in the December 19,1996, submittal.

i In the December 19,1996 submittal, Entergy Operations proposed the inclusion of the control radiation monitors as Functional Unit 18 on page 45d2 of Table 3.5.1-1. With the issuance of ANO-1 Amendment 192, these requirements were moved from page 45d2 to page 45dl, and the requirements associated with the seismic monitoring instrumentation, Functional Unit 14, l

were relocated. Entergy Operations proposes that the control room radiation monitor requirements now be included as Functional Unit 14. This change is editorial and reflects the i incorporation of a previously approved amednemnt.

The required actions of the proposed ANO-1 TS 3.9.1.2 and 3.9.2.2 have been revised for I

consistency with the associated limiting conditions for operation (LCO). These LCOs require two independent trains of the subject systems to be operable. However, the required actions require the restoration of the inoperable systems. The revised required actions now require the restoration of the inoperable ' train. A similar change has been incorporated in the 4 I

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. Attachment to OCAN089801 Page_4 of 5 proposed ANO-1 TS 4.10.2 which now requires each train of control room emergency ventilation to be demonstrated operable. These changes are considered to be editorial ,

, clarifications of the proposed specifications and have bcen determined to be bounded by the determination of no significant hazards consideration presented in the December 19, 1996, submittal.

ANO-2 TS Table 3.3-6, Radiation Monitoring Instrumentation, instrument 2b currently requires one channel of control room ventilation intake duct monitor to be operable. In the December 19,1996 submittal, Entergy Operations proposed a revision to this requirement to specify the operability of the ANO-1 control room area radiation monitor as well as the ANO-2 ventilation intake duct monitor. Since the new ANO-1 control room ventilation '

intake duct monitor is identical to the existing ANO-2 duct monitor with respect to method of operation, sensitivity, and setpoint, Entergy Operations proposes to revise the instrument 2b requirements to require 2 channels of control room ventilation intake monitors to be operable with a setpoint of s 2 times background and a measurement range of 10 to '10' cpm. The proposed ANO-2 TS Bases associated with TS 3/4.3.3.1 has been revised to replace the reference to the ANO-1 control room area radiation monitor with a reference to the ANO-1 control room ventilation intake duct monitor. For consistency in terminology, the reference to the ANO-2 control room ventilatica monitor has been eplaced with a reference to the ANO-2 control room ventilation intake duct monitor. Since the two monitors are identical, the

, inclusion of this requirement, and the discussion in the Bases, still results in a more restrictive specification than previously existed. Therefore, Entergy Operations has determined that this change is bounded by the determination of no significant hazards consideration presented in l the December 19,1996, submittal.

In the December 19, 1996, submittal,'Entergy Operations proposed changes to ANO-2 TS

Table 4.3-3, Instrument 2b to specify the surveillance requirements for both control room l - ventilation intake duct monitors for consistency with the requirements specified in TS Table 3.3-6, Radiation Monitoring Instrumentation, instrument 2b. Entergy Operations proposes to r revise our submittal such that instrument 2b is described as " Control Room Intake Duct Monitors." The only difference between this proposal and the current ANO-2 requirement is that plural monitors are required to be tested. This change is considered to be more restrictive l in nature and maintains consistency with the requirements proposed for TS Table 3.3-6.

Entergy Operations has determined that this change is bounded by the determination of no significant hazards consideration presented in the December 19,1996, submittal.

l Entergy Operations proposes to add an additional required action to those specified for ANO-2 TS 3.7.6.1. The required actions proposed in the December 19,19%, submittal provide direction to the operator in the event one control room emergency air conditioning system or one control room emergency ventilation system is inoperable. The proposed required actions did not provide explicit direction to the operator in the event one c : rol room emergency air conditioning system and one control room emergency ventilation system are inoperable. Due to the structure of the proposed ANO-2 actions, this condition could be interpreted as requiring entry into Limiting Condition for Operation (LCO) 3.0.3. Although this configuration is not single failure proof, the safety function is not lost. Therefore, an additional required action (Action c) has been proposed.

Attachment to OCAN089801 Page 5 of 5 This new action requires restoration of the inoperable control room emergency ventilation

' system within 7 days and restoration of the inoperable control emergency air conditioning system within 30 days, or place the unit in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This provides the operator with actions for this condition that are consistent with the required actions provided in NUREG-1432, " Standard Technical Specifications - Combustion Engineering Plants," Revision 1, dated April,1995.

The actions for this condition are also consistent with the interpretation of the actions proposed for ANO-1 TS 3.9.1 and TS 3.9.2 in our December 19, 1996, submittal. The inclusion of ANO-2 TS 3.7.6.1 Action c is considered to be an administrative clarification of I

the existing proposed requirements to prevent a misinterpretation that could result in an improper entry into the actions of LCO 3.0.3. Therefore, Entergy Operations has determined l that this change is bounded by the determination of no significant hazards consideration presented in the December 19,1996, submittal.

The incorporation of ANO-2 TS Amendment 191 resulted in the deletion of"or high chlorine" from ANO-2 Surveillance Requirement (SR) 4.7.6.1.2.d.2. This change has been reflected in the proposed ANO-2 TS page 3/4 7-18. ANO-2 Amendment 191 also relocated the Bases l information associated with the seismic instrumentation and meteorological instrumentation

on ANO-2 TS page B3/4 3-2, and has been incorporated in this submittal. This is considered to be an editorial correction incorporating a previously approved amendment.

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