2CAN049802, Application for Amend to License NPF-6,revising Value of Single Largest post-accident Load Capable of Being Supplied by DGs & Relocates Value to Associated Bases

Application for Amend to License NPF-6,revising Value of Single Largest post-accident Load Capable of Being Supplied by DGs & Relocates Value to Associated Bases

ML20217M256
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/30/1998
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217M260	List: 2CAN049802, Application for Amend to License NPF-6,revising Value of Single Largest post-accident Load Capable of Being Supplied by DGs & Relocates Value to Associated Bases ML20217M262
References
RTR-NUREG-1432 2CAN049802, 2CAN49802, NUDOCS 9805040474
Download: ML20217M256 (8)

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Ent:rgy oper:tions,Inc. I

%- y 1448 SR 333 l f }0 Lf fh a % AR 72801

, Tel 501858-4888 C. Randy Hutchinson We Presown Operators ANO April 30,1998 2CAN049802 l U.' S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137 Washington, DC 20555

Subject:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 <

Proposed Technical Specification Change Revising Diesel Generator Load l Rejection Testing l 1

Gentlemen: l 4

Attached for your review and approval is a proposed change to the Arkansas Nuclear One -

Unit 2 (ANO-2) Technical Specification (TS) 4.8.1.1.2.c.3 requirements for diesel generator testing. The proposed change revises the value of the single largest post-accident load capable of being supplied by the diesel generators and relocates this value to the associated bases. The revised value is the result of revisions to the diesel generator loading calculation and the relocation of the value to the bases is consistent with the testing requirements <

specified in NUREG-1432, " Standard Technical Specifications-Combustion Engmeenng j Plants, Rev 1, dated April,1995.

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.

I Entergy Operations requests that the effective date for this change be within 30 days of NRC j issuance of the amendment to allow for distribution and procedural implementation of the j revised requirements. Although this request is neither exigent nor emergency, your prompt i review is requested. ,

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. . April 30,1998 2CAN049802 Page 2 Very truly yo rs, jg

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C cws 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 P blic in and for Nw County and the State of Arkansas, this Jo%ay of ,1998. /

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" OFFICIAL SEAlf.::::_::1

. Andrea Pierce

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!- U. S. NRC April 30,1998 l 2CAN049802 Page 3 i

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Mr. Ellis W. Merschoff l Regional Administrator l U. S. Nuclear Regulatory Commission l RegionIV L 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064

NRC Senior Resident Inspector l Arkansas Nuclear One P.O. Box 310 London, AR72847

' 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 l Rockville, MD 20852 l

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! ' Mr. David D. Snellings l Director, Division of Radiation Control and Emergency Management l Arkansas Department ofHealth j I

4815 West Markham Street Little Rock, AR 72205 l l

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j ATTACHMENT IQ 2CAN049802 PROPOSED TECHNICAL SPECIFICATION l t

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RESPECTIVE SAFETY ANALYSES l IN THE MATTER OF AMENDING l

LICENSE NO. NPF-6 l

l ENTERGY OPERATIONS. INC. i ARKANS AS NUCLEAR ONE. UNIT TWO l

-l DOCKET NO. 50-368 l l l l

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. 2CAN049802 Page 1 of 2 j i

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. ' DESCRIPTION OF PROPOSED CHANGES Adansas Nuclear One - Unit ? (ANO-2) Technical Specification (TS) 4.8.1.1.2.c.3 has been revised to relocate the specific value for the single largest post-accident load to the Bases associated with TS 4.8. TS 4.8.1.1.2.c.3 now requires the licensee to verify the generator l

. capability to reject a load greater than or equal to its associated single largest post-accident load, consistent with the requirements of NUREG-1432 for diesel generator load rejection testing.

1 BACKGROUND l Each ANO-2 Emergency Diesel Generator (EDG) is provided with an engine overspeed tnp i to prevent damage to the engine. The surveillance test required by TS 4.8.1.2.c.4 j demonstrates the DG capability to reject a full load without overspeed tripping or exceeding  !

predetermined speed limits. The surveillance test required by TS 4.8.1.1.2.c.3 demonstrates )

the DG load response characteristics and capability to reject the largest single load without j exceeding predetermined voltage and frequency and while maintaining a specified margin to i the overspeed trip. For the ANO-2 DGs, the largest single post-accident load is the associated Service Water (SW) pump. The ANO-2 DGs are described in ANO-2 Safety Analysis Report (SAR) Section 8.3.1.1.9. SAR Table 8.3-1, Diesel Load Table, specifies the expected DG post-accident loads.

DISCUSSION OF CHANGE As a result of a review of calculations associated with the ANO-2 DGs, it was discovered that the value currently specified in TS 4.8.1.1.2.c.3 (596 kW) represented the horsepower rating of the SW pump, assuming 100% efficiency. A revised calculation, utilizing design SW flow, the SW pump horsepower rating from SAR Table 8.3-1, and the pump manufacturer's stated efficiency of 92.5%, determined the appropriate DG load due to the SW pump to be 636.9 kW. ,

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NUREG-1432 Surveillance Requirement (SR) 3.8.1.9, which corresponds to ANO-2 TS 4.8.1.1.2.c.3, does not contain the specific value of the largest load. It makes reference to the largest load, which is then described in the Bases associated with SR 3.8.1.9. Since the j NUREG-1432 Bases gives the largest load in horsepower, the ANO-2 TS 4.8 Bases have l been revised to include the largest single load horsepower from SAR Table 8.3-1, in addition to the kW rating from the DG load calculation.

By letter dated June 21,1995 (OCAN069502), Entergy Operations committed to the ,

conversion of the ANO-2 TS to the format of NUREG-1432. This proposed change is not i intended to fully incorporate all NUREG-1432 DG requirements. It is only intended to allow the correction of incorrect information in the ANO-2 TS, consistent with the similar requirements of NUREG-1432. The remainder of the DG requirements contained in

. NUREG-1432 will be evaluated for inclusion during the conversion process for ANO-2.

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DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION 4 l

An evaluation of the proposed change has bmi performed in accordance with 10CFR50.91(a)(1) regarding no significant Mzards considerations using the standards in ,

L 10CFR50.92(c). A discussion of these statidards ris they relate to this amendment request follows:

a Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequenecs of an Accident Previously Evaluated.  !

, j The Diesel Generators (DGs) are not identified as the initiator of any accident previously I analyzed. The design and function of the DGs are unaffected by this proposed change.

l Applying more restrictive acceptance criterion to the single largest load rejectio i test can not result in an increase in the probability of accidents previously evaluated and will provide increased assurance that the DGs will perform as intended to support the mitigation of. 4 accidents previously evaluated.

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Therefore, this ~ change does not involve a signi6 cant increase in the probability or i consequences of any accident previously evaluated.

Criterion 3 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.

The proposed change co:Tects information contained in the technical specification and does l

not involve any design change, plant modification, change in analyzed DG performance, or l

change in plant operation. Since the DGs are not considered to be event initiators, their accident mitigation function is unaffected, and normal operation is unaffected, the proposed change does not result in new or different accidents from those previously analyzed.

Therefore, this change does agt create the possibility of a new or different kind of accident from any previously evaluated.

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

The design and function of the DGs are unaffected by the proposed change. Applying more restrictive acceptance criterion to the single largest load rejection test will provide increased assurance that the DGs will perform as intended to support the mitigation of postulated accidents. DG performance is proposed to meet a more stringent standard.

Therefore, this change does n_glinvolve a significant reduction in the margin of safety.

Therefore, based upon the reasoning presented above and the previous discussion of the amendment request, Entergy Operations has determined that the requested change does agl involve a significe.nt hazards consideration.

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