2CAN041905, License Amendment Request: Application to Revise Technical Specifications to Adopt TSTF 563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program
| ML19120A086 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/30/2019 |
| From: | Gaston R Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN041905 | |
| Download: ML19120A086 (14) | |
Text
Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 2CAN041905 April 30, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
License Amendment Request Application to Revise Technical Specifications to Adopt TSTF 563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program" Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 Pursuant to 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-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program." TSTF-563 revises the TS definitions of Channel Calibration and Channel Functional Test. The definition of Channel Calibration currently permits performance by any series of sequential, overlapping, or total channel steps. The definition of Channel Functional Test is revised to explicitly permit performance by means of any series of sequential, overlapping, or total channel steps. Both definitions are revised to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.
The enclosure provides a description and assessment of the proposed changes. Attachment 1 of the enclosure provides the existing TS pages marked to show the proposed changes. of the enclosure provides revised (clean) TS pages.
No new regulatory commitments are included in this amendment request.
Approval of the proposed amendment is requested by May 1, 2020. Once approved, the amendment shall be implemented within 60 days.
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.
2CAN041905 Page 2 of 2 If there are any questions or if additional information is needed, please contact Tim Arnold at 479-858-7826.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 30, 2019.
Sincerely, ORIGINAL SIGNED BY RON GASTON Ron Gaston RG/dbb
Enclosure:
Description and Assessment cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205
Enclosure to 2CAN041905 Description and Assessment
Enclosure to 2CAN041905 Page 1 of 5
1.0 DESCRIPTION
Entergy Operations, Inc. (Entergy) requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program." TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test.
The definition of Channel Calibration currently permits performance by any series of sequential, overlapping, or total channel steps. The definition of Channel Functional Test is revised to explicitly permit performance by means of any series of sequential, overlapping, or total channel steps. Both definitions are revised to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program (SFCP).
2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test. The definition of Channel Calibration currently permits performance by any series of sequential, overlapping, or total channel steps. The definition of Channel Functional Test is revised to explicitly permit performance by means of any series of sequential, overlapping, or total channel steps. Both definitions are revised to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.
A SFCP was incorporated into the ANO-2 TS in a license amendment dated April 23, 2019 (ML19063B948).
2.2 Optional Changes and Variations Entergy is proposing the following variations from the TS changes described in the TSTF-563 or the applicable parts of the NRC staffs safety evaluation. The ANO-2 TS contain requirements that differ from the Standard Technical Specifications (STS) on which TSTF-563 was based, but are encompassed in the TSTF-563 justification.
a) The ANO 2 TS are different from Revision 4 of the Combustion Engineering (CE) Plant STS (NUREG-1432) on which TSTF-563 is based. The definition of Channel Calibration has wording differences from the STS definition that do not change the intent. The ANO-2 TS Channel Calibration definition states, "The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated." The STS states, "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps."
Addition of the words "means of" is editorial, and elimination of the phrase "such that the entire channel is calibrated" has no effect because the definition previously states that the Channel Calibration must encompass the entire channel.
b) The ANO 2 TS definition of Channel Functional Test does not include a provision to perform the test by means of any series of sequential, overlapping, or total channel steps.
However, the existing Channel Calibration definition explicitly includes the Channel Functional Test and permits performance of the Channel Calibration by means of any series of sequential, overlapping, or total channel steps. As discussed in the TSTF-563
Enclosure to 2CAN041905 Page 2 of 5 justification, applying the allowance to determine the appropriate Frequency for each step based on the components tested in each Channel Functional Test step avoids potential conflicts between the definitions. Further, this is consistent with the STS which permits performance of the Channel Functional Test by means of any series of sequential, overlapping, or total channel steps.
This provision to perform the Channel Functional Test by means of any series of sequential, overlapping, or total channel steps appeared in the original CE STS and was added to the other STS definitions of Channel Functional Test by TSTF-205-A, Revision 3, "Revision of Channel Calibration, Channel Functional Test, and Related Definitions," which was approved by the NRC on January 13, 1999, and incorporated into Revision 2 of the STS. TSTF-205 described the change:
Other changes are made for consistency of the definitions between the ISTS NUREGs.
The NUREG-1430 Channel Functional Test and NUREG 1431 Channel Operational Test definitions are modified to include the sentence, "The CHANNEL FUNCTIONAL (OPERATIONAL for NUREG 1431) TEST may be performed by means of any series of sequential, overlapping, or total channel steps." This allowance currently exists in the CEOG, BWR/4 and BWR/6 definitions of Channel Functional Test and is understood to apply to the BWOG and WOG definitions, although not stated. The changes proposed increase the consistency of the five NUREGs and are not intended to change the meaning or intent of the affected definitions. (emphasis added)
The addition of this sentence to the Channel Functional Test definition is necessary to adopt TSTF-563 and, as stated in TSTF-205, already existed in the CE STS. Therefore, adding the sentence does not change the intent of the existing definition and permits adoption of TSTF-563.
c) The traveler and Safety Evaluation 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-563 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.
Enclosure to 2CAN041905 Page 3 of 5 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-563 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.
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 ANALYSIS
3.1 No Significant Hazards Consideration Analysis Entergy Operations, Inc. (Entergy) requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program." TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test.
The definition of Channel Calibration currently permits performance by any series of sequential, overlapping, or total channel steps. The definition of Channel Functional Test is revised to explicitly permit performance by means of any series of sequential, overlapping, or total channel steps. Both definitions are revised to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program (SFCP).
Enclosure to 2CAN041905 Page 4 of 5 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 amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. All components in the channel continue to be tested. The frequency at which a channel test is performed is not an initiator of any accident previously evaluated; therefore, the probability of an accident is not affected by the proposed change. The channels surveilled in accordance with the affected definitions continue to be required to be operable and the acceptance criteria of the surveillances are unchanged. As a result, any mitigating functions assumed in the accident analysis will continue to be performed.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?
Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. The design function or operation of the components involved are not affected and there is no physical alteration of the plant (i.e.,
no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are introduced. The changes do not alter assumptions made in the safety analysis.
The proposed changes are consistent with the safety analysis assumptions.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. The SFCP assures sufficient safety margins are maintained, and that the design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis. The
Enclosure to 2CAN041905 Page 5 of 5 proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by method of determining surveillance test intervals under an NRC-approved licensee-controlled program.
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.
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.
4.0 ENVIRONMENTAL EVALUATION 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 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.
ATTACHMENTS
- 1. Technical Specification Page Markups
- 2. Revised Technical Specification Pages
Enclosure Attachment 1 to 2CAN041905 Technical Specification Page Markups (2 pages)
DEFINITIONS CONTAINMENT INTEGRITY 1.8 CONTAINMENT INTEGRITY shall exist when:
1.8.1 All penetrations required to be closed during accident conditions are either:
- a. Capable of being closed by an OPERABLE containment automatic isolation valve system, or
- b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1.
1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each airlock is OPERABLE pursuant to Specification 3.6.1.3, 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows or O-rings) is OPERABLE.
CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the stepsuch that the entire channel is calibrated.
CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
ARKANSAS - UNIT 2 1-2 Amendment No. 154,157,
DEFINITIONS CHANNEL FUNCTIONAL TEST 1.11 A CHANNEL FUNCTIONAL TEST shall be:
- a. Analog channels - The injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions.
- b. Bistable channels - The injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.
- c. Digital computer channels - The exercising of the digital computer hardware using diagnostic programs and the injection of simulated process data into the channel to verify OPERABILITY.
The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CORE ALTERATION 1.12 CORE ALTERATION shall be the movement or manipulation of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position.
SHUTDOWN MARGIN 1.13 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all control element assemblies are fully inserted except for the single assembly of highest reactivity worth which is assumed to be fully withdrawn.
IDENTIFIED LEAKAGE 1.14 IDENTIFIED LEAKAGE shall be:
- a. Leakage (except controlled leakage) into closed systems, such as pump seal or valve packing leaks that are captured, and conducted to a sump or collecting tank, or
- b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or
- c. Reactor coolant system leakage through a steam generator to the secondary system (primary to secondary leakage).
ARKANSAS - UNIT 2 1-3 Amendment No. 157,220,255,266,
Enclosure Attachment 2 to 2CAN041905 Revised Technical Specification Pages (2 pages)
DEFINITIONS CONTAINMENT INTEGRITY 1.8 CONTAINMENT INTEGRITY shall exist when:
1.8.1 All penetrations required to be closed during accident conditions are either:
- a. Capable of being closed by an OPERABLE containment automatic isolation valve system, or
- b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1.
1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each airlock is OPERABLE pursuant to Specification 3.6.1.3, 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows or O-rings) is OPERABLE.
CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
ARKANSAS - UNIT 2 1-2 Amendment No. 154,157,
DEFINITIONS CHANNEL FUNCTIONAL TEST 1.11 A CHANNEL FUNCTIONAL TEST shall be:
- a. Analog channels - The injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions.
- b. Bistable channels - The injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.
- c. Digital computer channels - The exercising of the digital computer hardware using diagnostic programs and the injection of simulated process data into the channel to verify OPERABILITY.
The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CORE ALTERATION 1.12 CORE ALTERATION shall be the movement or manipulation of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position.
SHUTDOWN MARGIN 1.13 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all control element assemblies are fully inserted except for the single assembly of highest reactivity worth which is assumed to be fully withdrawn.
IDENTIFIED LEAKAGE 1.14 IDENTIFIED LEAKAGE shall be:
- a. Leakage (except controlled leakage) into closed systems, such as pump seal or valve packing leaks that are captured, and conducted to a sump or collecting tank, or
- b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or
- c. Reactor coolant system leakage through a steam generator to the secondary system (primary to secondary leakage).
ARKANSAS - UNIT 2 1-3 Amendment No. 157,220,255,266,