ML071220178

License Amendment Request - to Delete the Fuel Handling Area Ventilation System and Associated Filter Testing Program Requirements

ML071220178
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/24/2007
From:	Mitchell T Entergy Operations
To:	Document Control Desk, NRC/NRR/ADRO
References
OCAN040701
Download: ML071220178 (22)

Text

a Entergy Operations, Inc.

Entergy 1448 SR. 333 Russellville, AR 72802 Tel 479-858-3110 Timothy G. Mitchell Vice President Operations ANO OCAN040701 April 24, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request To Delete the Fuel Handling Area Ventilation System and Associated Filter Testing Program Requirements Arkansas Nuclear One, Unit I and Unit 2 Docket No. 50-313 and 50-368 License No. DPR-51 and NPF-6

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests an amendment for Arkansas Nuclear One, Unit I (ANO-1) and Unit 2 (ANO-2). The proposed change will result in the deletion of the Fuel Handling Area Ventilation System (FHAVS) and associated Ventilation Filter Testing Program (VFTP) requirements that are included in the ANO-1 Technical Specifications (TSs) 3.7.12 and 5.5.11 and the ANO-2 TS 3.9.11 and 6.5.11. Filter testing requirements for the FHAVS will be maintained in a licensee controlled document that is governed under 10 CFR 50.59, Changes, tests, and experiments.

The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations are included in the attached submittal.

The proposed change includes new commitments as summarized in Attachment 4.

Entergy requests approval of the proposed amendment by April 18, 2008. Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

4uDI

OCAN040701 Page 2 of 2 If you have any questions or require additional information, please contact Dana Millar at 601-368-5445.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 24, 2007.

Sincerely, TGM/DM Attachments:

1. Analysis of Proposed Technical Specification Change

2. ANO-1 Proposed Technical Specification Changes (mark-up)

3. ANO-2 Proposed Technical Specification Changes (mark-up)

4. List of Regulatory Commitments cc: Dr. Bruce S. Mallett 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 U. S. Nuclear Regulatory Commission Attn: Ms. Farideh E. Saba MS O-8B1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health and Human Services P. O. Box 1437 Slot H-30 Little Rock, AR 72203-1437

Attachment I OCAN040701 Analysis of Proposed Technical Specification Change

Attachment I to OCAN040701 Page 1 of 9

1.0 DESCRIPTION

This letter is a request to amend Operating Licenses DPR-51 and NPF-6 for Arkansas Nuclear One, Unit I (ANO-1) and Unit 2 (ANO-2), respectively.

The proposed change will delete the Fuel Handling Area Ventilation System (FHAVS) and associated Ventilation Filter Testing Program (VFTP) requirements that are included in the ANO-1 Technical Specifications (TSs) 3.7.12 and 5.5.11 and the ANO-2 TSs 3.9.11 and 6.5.11. The requirements will be relocated to a licensee controlled document, the unit specific Technical Requirements Manuals (TRM), which are controlled under 10 CFR 50.59, Changes, tests, and experiments.

With the deletion of the FHAVS from the TS, the ANO-1 and ANO-2 FHAVS filtration testing will be performed consistent with the guidance in Regulatory Guide 1.140, Revision 1, dated October 1979, Design, Testing, and Maintenance Criteriafor Normal Ventilation Exhaust System Air Filtrationand Adsorption Units of Light-Water-CooledNuclearPower Plants.

Regulatory Guide 1.140, Revision 1 requires filter testing once per 18 months, a change from the current requirement to test after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation.

2.0 PROPOSED CHANGE

The ANO-1 and ANO-2 TSs include requirements to maintain the FHAVS during movement of irradiate fuel assemblies in the fuel handling area (TS 3.7.12 and TS 3.9.11, respectively) and also include filter testing requirements for the FHAVS In the Ventilation Filtration Testing Program (TS 5.5.11 and TS 6.5.11, respectively). The proposed change will delete these requirements.

2.1 ANO-1 The ANO-1 TS for FHAVS (TS 3.7.12), the associated actions and surveillance requirements will be deleted.

The ANO-1 program (TS 5.5.11) is applicable to the Penetration Room Ventilation System (PRVS), the FHAVS, and the Control Room Emergency Ventilation System (CREVS).

The proposed change will delete the following from ANO-1 TS 5.5.11:

" The requirement to demonstrate that an Inplace cold dioctyl phthalate (DOP) test of the high efficiency particulate (HEPA) filter shows > 99% DOP removal for the FHAVS when tested at the system design flowrate of 39,000 cfm +/- 10%

(TS 5.5.11 a.1);

" The requirement to demonstrate that an Inplace halogenated hydrocarbon test of the charcoal adsorbers shows > 99% halogenated hydrocarbon removal for the FHAVS when tested at the system design flowrate of 39,000 cfm +/- 10%

(TS 5.5.11 b.1);

Attachment I to OCAN040701 Page 2 of 9

• The requirement to demonstrate that a laboratory test of a sample of the charcoal adsorber meets the laboratory test criteria of ASTM D 3803-1989 when tested at 30 ° C and 95% relative humidity for a methyl iodide penetration of < 5% for the FHAVS (TS 5.5.11 c.2); and

• The requirement to demonstrate for the FHAVS that the pressure drop across the combined HEPA filters, other filters in the system, an the charcoal adsorbers is

< 6 inches of water when tested at the system design flowrate of 39,000 cfm

+/- 10% (TS 5.5.11 d).

Filtration testing requirements for the PRVS and CREVS will not be changed. The requirements for the FHAVS and the associated filtration testing will be maintained in the ANO-1 TRM, however, the frequencies for testing may be modified in accordance with 10 CFR 50.59.

2.2 ANO-2 The ANO-2 TS for FHAVS (TS 3.9.11), the associated actions and surveillance requirements will be deleted.

The ANO-2 program (TS 6.5.11) is applicable to the FHAVS and the Control Room Emergency Ventilation System (CREVS). The proposed change will delete the following for ANO-2 TS 6.5.11:

" The requirement to demonstrate that an inplace cold DOP test of the high efficiency particulate (HEPA) filter shows > 99% DOP removal for the FHAVS when tested at the system design flowrate of 39,700 cfm +/- 10% (TS 6.5.11 a.1);

• The requirement to demonstrate that an inplace halogenated hydrocarbon test of the charcoal adsorbers shows > 99.95% halogenated hydrocarbon removal for the FHAVS when tested at the system design flowrate of 39,700 cfm +/- 10%

(TS 6.5.11 b.1);

• The requirement to demonstrate that a laboratory test of a sample of the charcoal adsorber meets the laboratory test criteria of ASTM D 3803-1989 when tested at 30 0 C and 95% relative humidity for a methyl iodide penetration of <5% for the FHAVS (TS 6.5.11 c.1); and

" The requirement to demonstrate for the FHAVS that the pressure drop across the combined HEPA filters, other filters In the system, an the charcoal adsorbers is

< 6 inches of water when tested at the system design flowrate of 39,700 cfm

+/- 10% (TS 6.5.11 d).

Filtration testing requirements for the CREVS will not be changed. The requirements for the FHAVS and the associated filtration testing will be maintained In the ANO-2 TRM, however, the frequencies for testing may be modified in accordance with 10 CFR 50.59.

Minor editorial changes are proposed In the ANO-1 and ANO-2 TSs to accommodate the deletion of text. No discussion is provided.

In summary, the proposed change will delete the ANO-1 and ANO-2 FHAVS TS and associated filtration testing requirements. In addition, the associated TS Bases will be deleted.

Attachment I to OCAN040701 Page 3 of 9

3.0 BACKGROUND

The Fuel Handling Area Ventilation Systems (FHAVS) for ANO-1 and ANO-2 maintain a suitable environment for equipment operation and personnel access. They were originally designed to filter any gaseous radioactivity that may occur during normal or accident conditions (i.e., a fuel handling accident). On this basis, the system is currently classified and designed as an Engineered Safety Features (ESF) air cleanup system.

The FHAVS is used during movement of Irradiated fuel, crane operation with loads over the Spent Fuel Pool (SFP), fuel shipments, and spent resin transfer to pull possible airborne radioactivity from the Train Bay by re-positioning manual dampers.

3.1 ANO-1 Spent Fuel Pool (SFP) Ventilation Exhaust fans (VEF-14A/B) consist of two redundant vane-axial fans in parallel. The fans are mounted in the same housing and draw air through the same filter bank. For normal operation one fan is started in manual with the second selected to auto for standby operation. Upon loss of the running fan the standby fan will be started.

The spent fuel ventilation flow-path draws air from the SFP area through three-element filters consisting of a roughing or pre-filter, a high-efficiency (HEPA) filter, and a charcoal filter (for radioactive iodine removal). The roughing filter is a standard pre-filter, and will stop most dust and particulate matter In the system. The high-efficiency filter is designed to capture 99.97% of particles 0.3 pm and larger. The charcoal filter is used to trap radioactive particles, specifically Methyl Iodide, at a removal efficiency commensurate with that assumed in the governing calculations. A high differential pressure alarm across the three-element filter is annunciated in the ANO-1 control room.

The discharge of VEF-14A/B is monitored for radioactivity by a Super Particulate Iodine and Noble Gas Monitor (SPING 3) which is part of the Radiological Dose Assessment Computer System (RDACS).

3.2 ANO-2 Similar to Unit 1, the fuel handling area exhaust fans (2VEF-14A/B) consist of two redundant vane-axial fans in parallel. The fans are mounted in the same housing and draw air through the same filter bank. For normal operation one fan is started in manual with the second selected to auto for standby operation. Upon loss of the running fan the standby fan will be started.

The spent fuel ventilation flow-path draws air from the SFP area through three-element filters consisting of a roughing or pre-filter, a high-efficiency (HEPA) filter, and a charcoal filter (for radioactive Iodine removal). The roughing filter is a standard pre-filter, and will stop most dust and particulate matter in the system. The high-efficiency filter Is designed to capture 99.97% of particles 0.3 pm and larger. The charcoal filter is used to trap radioactive particles, specifically Methyl Iodide, at a removal efficiency commensurate with that assumed in the governing calculations. A high differential pressure alarm across the three-element filter Is annunciated in the ANO-2 control room.

Attachment I to OCAN040701 Page 4 of 9 The fuel handling exhaust air radiation monitor (2RE-8540) and SPING 7 continuously monitor the gaseous activity of the exhaust air flow path.

3.3 HEPA Filter Testing Section 6.5.4 of the ANO-2 Safety Analysis Report (SAR) defines the HEPA filter testing as follows:

"Each HEPA filter is tested with thermally generated DOP of uniform 0.3 micron droplet size in accordance with Edgewood Arsenal Manual Documents No. 136-300 - 195A and No. 136-300 - 175A. System efficiency is to be within tolerance of 99.97 percent when measured by means of a portable photometer upstream and downstream of the filter. A downstream concentration of greater than 0.03 percent (99.97 percent efficient) indicates that the integrated penetration reading is unsatisfactory and the individual cells and their gaskets must be tested to locate any leaks. Corrective action shall then be taken and the procedure repeated until the bank tests satisfactorily.

Testing of the charcoal adsorbers will follow the recommended methods as specified In Oak Ridge National Lab Manual, Nuclear Safety Information Center ORNL-NSIC-65 Design, Construction and Testing, of High Efficiency Air Filtration Systems for Nuclear Application by C.A. Burchstead and A.B. Fuller.

The charcoal adsorbers are tested by the use of Refrigerant-1 1 (R-1 1) introduced on the upstream side of the filters.

Instrumentation will provide for measuring the relative upstream and downstream concentrations of R-1 1. Leakage greater than 0.05 % across the adsorber banks will require corrective action."

Although not explicitly defined in the ANO-1 SAR, a similar testing method Is employed for ANO-1.

3.4 Summary Typically, one of the fans on each unit runs continuously due to the high volume of schedule maintenance (e.g., dry cask loading activities, fuel receipt, etc.) In the SFP area. In accordance with the note "c" on Table 2 of Regulatory Guide 1.52, laboratory testing for activated charcoal Is required after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, which results In monthly filtration testing. The proposed change will result in the deletion of the testing requirements defined in Regulatory Guide 1.52; however, filtration testing will continue to be performed In accordance with Regulatory Guide 1.140.

4.0 TECHNICAL ANALYSIS

Standard Review Plan (SRP) 15.7.4, RadiologicalConsequences of Fuel HandlingAccidents, requires that the dose consequences of a FHA must be well within the limits given in 10 CFR 100. "Well within" Is further defined in this SRP as 25% of the 10 CFR 100 limits.

This results in an offsite dose limit of 6 rem to the whole body and 75 rem to the thyroid for the duration of the accident.

Attachment I to 0CAN040701 Page 5 of 9 The offsite and control room dose consequences of a fuel handling accident (FHA) in the respective unit's SFP area have been performed for both units without FHAVS filtration. The results indicate that offsite dose consequences are well within the regulatory limits without credit for FHAVS filtration.

Each analysis considered the basic assumptions and regulatory position given in Regulatory Guidance 1.25 (RG), Assumptions Used for Evaluatingthe PotentialRadiological Consequences of a Fuel HandlingAccident in the Fuel Handlingand Storage Facilityfor Boiling And PressurizedWater Reactors.

Section C.1 .d of RG 1.25 states that "all of the gap activity In the damaged rods Is released and consists of 10% of the total noble gas other than Kr-85, 30% of the Kr-85, and 10% of the total radioactive Iodine in the rods at the time of the accident. For the purpose of sizing filters for the fuel handling accident addressed in this guide, 30% of the 1-127 and 1-129 inventory is assumed to be released from the damaged fuel." The assumptions used in generating the fuel gap activity is consistent with this regulatory position with the exception that the release fraction of Iodine-1 31 is Increased by 20% (i.e., from 10% to 12%) in accordance with NUREG/CR-5009, Assessment of the Use of Extended Bumup Fuel in Light Water Reactors, February 1988. NUREG/CR-5009 discusses the variations in plenum inventories for extended bumup fuel. Table 3.6 of NUREG/CR-5009 Indicates that the Iodine-131 Inventory is 20% higher than in RG 1.25 for rod burnups of 60 GWD/MTU. Therefore, the gap activity for iodine is assumed to be 12% for ANO-1 and ANO-2.

No other exceptions were taken to the basic assumptions provided in RG 1.25.

4.1 ANO-1 The following results assumed 82 fuel rods failed with no filtration through the fuel handling ventilation filtration system. In addition, Control Room inleakage was maximized.

Dose Category Exclusion Area Control Room Control Room Boundary (2 Hour) Rem Rem Rem (10 cfm inleakage) (98 cfm inleakage)

Whole Body 2.948E-01 4.644E-02 5.279E-02 Skin (Note 1) 1.166 3.751 4.257 Thyroid 6.912E+01 4.097 2.981E+01 Note I - the "total" skin dose resulting from gamma and beta radiation.

Attachment I to OCAN040701 Page 6 of 9 4.2 ANO-2 The following results assumed the failure of 60 fuel rods with no credit for the fuel handling ventilation filtration system. These results reflect the ANO-2 design basis FHA.

Dose Category Exclusion Area Control Room Control Room Boundary (2 Hour) Rem Rem Rem (10 cfm Inleakage) . (61 cfm inleakage)

Whole Body 9.985E-02 3.245E-03 3.519E-03 Skin (Note 1) 3.750E-01 2.519E-01 2.724E-01 Thyroid 5.289E+01 6.722E-01 3.162 Note 1 -the "total" skin dose resulting from gamma and beta radiation.

4.3 Summary The ANO-1 and ANO-2 analyses of the FHA in the SFP area demonstrate that the FHAVS does not perform a safety function required to mitigate the consequences of an accident.

Offsite and control room doses are within the allowable limits with no filtration credited. On this basis the classification of the system as an ESF air cleanup system may be downgraded.

5.0 REGULATORY ANALYSIS

The proposed change will delete the Fuel Handling Area Ventilation System (FHAVS) and associated Ventilation Filter Testing Program (VFTP) requirements that are included in the Arkansas Nuclear One, Unit I (ANO-1) Technical Specifications (TS) and Arkansas Nuclear One, Unit 2 (ANO-2) TS. The requirements will be relocated to a licensee controlled document, the unit specific Technical Requirements Manuals (TRM), which are controlled under 10 CFR 50.59, Changes,tests, and experiments.

5.1 Applicable Regulatorv RequlrementslCriterla The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

General Design Criteria (GDC) 60 and 61 of Appendix A, GeneralDesign Criteriafor Nuclear Power Plants,to 10 CFR Part 50, Domestic Licensing of Productionand Utilization Faculties, require that filtering systems be included In the nuclear power unit design to control suitably the release of radioactive materials In gaseous effluents during normal reactor operation, including anticipated operational occurrences and fuel storage and handling operations. In addition, 10 CFR 50.34a, Design objectives for equipment to controlreleases of radioactive materialIn effluents -nuclear power reactors,and 10 CFR 50.36a, Technical specificationson effluents from nuclearpower reactors,require that means be employed to ensure that release of radioactive material to unrestricted areas during normal reactor operations, Including expected operations occurrences, is kept as low as Is reasonably achievable.

Attachment I to 0CAN040701 Page 7 of 9 Considering the proposed change Entergy continues to satisfy the design objects that are defined in GDC 60 and 61 and 10 CFR 50.34a. No plant modifications are planned to remove the ANO-1 or ANO-2 FHAVS.

10 CFR 50.36, Technical Specifications, lists four criterion that require the establishment of a Limiting Condition for Operation. The following provides comparison of these four criterions with the basis for the ANO-1 and ANO-2 FHAVS.

Criterion 1 - Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

The FHAVS is not used to detect degradation of any type associated with the reactor coolant pressure boundary.

Criterion 2 - A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The FHAVS provides a means of air filtration during normal and accident conditions and is not an initial condition of a design basis accident or transient analysis associated with the integrity of a fission product barrier.

Criterion 3 - A structure, system, or component that Is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the Integrity of a fission product barrier.

The FHAVS provides a means of air filtration during normal and accident conditions. Analysis has demonstrated that when the filtration system is not In service, the dose consequences of a fuel handling accident (FHA) are well within the limits given in 10 CFR 100. Therefore, the FHAVS is not needed for the successful mitigation of a FHA.

Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The FHAVS is not a risk significant system. Analysis has demonstrated that when the filtration system is not in service the dose consequences of a fuel handling accident (FHA) are well within the limits'given in 10 CFR 100.

Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any GDC differently than described in the unit specific Safety Analysis Report (SAR.)

5.2 No Significant Hazards Consideration Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

Attachment I to OCAN040701 Page 8 of 9

1. Does the proposed change involve a significant Increase In the probability or consequences of an accident previously evaluated?

Response: No.

The FHAVS is not involved in the initiation of any accidents. The system maintains a suitable environment for equipment operation and personnel access. They are also designed to filter any gaseous radioactivity that may occur during normal or accident conditions (i.e., a fuel handling accident). On this basis, the system is currently classified and designed as an Engineered Safety Features (ESF) air cleanup system.

The FHAVS is used during movement of irradiated fuel, crane operation with loads over the Spent Fuel Pool (SFP), fuel shipments, and spent resin transfer to pull possible airborne radioactivity from the Train Bay by re-positioning manual dampers.

Revised ANO-1 and ANO-2 analysis of the dose consequences of a FHA, to both the public and to the control room operator, demonstrate that doses remain well within regulatory acceptance limits without crediting filtration. Thus there is no required safety function for the ANO-1 or ANO-2 FHAVS.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The FHAVS is not Involved in the initiation of any accidents. It was designed to filter any gaseous radioactivity that may occur during normal or accident conditions (i.e., a fuel handling accident). No physical modifications are planned to the ANO-1 or ANO-2 FHAVS.

Revised ANO-1 and ANO-2 analysis of the dose consequences of a FHA, to both the public and to the control room operator, demonstrate that doses remain well within regulatory acceptance limits without crediting filtration. Thus there is no required safety function for the ANO-1 or ANO-2 FHAVS.

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 change involve a significant reduction in a margin of safety?

Response: No.

The FHAVS was designed to filter any gaseous radioactivity that may occur during normal or accident conditions (i.e., a fuel handling accident). No physical modifications are planned to the ANO-1 or ANO-2 FHAVS.

Attachment I to OCAN040701 Page 9 of 9 Revised ANO-1 and ANO-2 analysis of the dose consequences of a FHA, to both the public and to the control room operator, demonstrate that doses remain well within regulatory acceptance limits without crediting filtration. The margin of safety, as defined in Standard Review Plan 15.7.4, Revision 1, and GDC 19, has not been significantly reduced.

Therefore, the proposed change does not Involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed amendment present 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.

5.3 Environmental Considerations The proposed amendment does not Involve (i) a significant hazards consideration, (ii) a significant change in the types or significant Increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment 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 amendment.

6.0 PRECEDENCE A similar change was reviewed and approved for Waterford Steam Electric Station, Unit 3 (WF3) by letter dated November 21, 2001 from the Nuclear Regulatory Commission to WF3 (TS Amendment No. 176).

Attachment 2 OCAN040701 ANO-1 Proposed Technical Specification Changes (mark-up)

FHAVS 3.7.12 3.7 PL'A.NT-SYSTEMS

'2 7 12 ~.Manl~igpcrj ue g I*IU Ar~g a Vantilation

...... ~.-I Sut (HAVIS!

~L.. 11 IA~ l~ .LIt L.. ~I~IE% A t~I g~ ... ~j 2...

I. 14e pmqm.4--

3-U3; shfll be Q I--AK andU inl opeLa.Itar.

APPLIP6CABII Il Duri;ng move-ment of irradiated fuel assemblies in the fue! handling iTY:

ara NOTE L-COC 23.00.3 i6 not applirable.

G"NDQiT'N REQUIRE)D ACT"lO COPLETIrN TIME A. F-HAVS inpenaber 8 rnt ir' AA1 SUpnmvmel mediately operation. irr-ad-imte-d fuel assem~blie6 n heful andlin aea-SURVEILLANCE REQUIREMENTS SURVEI LLA.NCE ,FREQUENGY S;R 3.7.12.1 VoifyFrH.4AA/S iOpe; r lation. ,2- trs S-R 3.7.12.2 PcrfoFrm required FHAVS filter testing in accordance in ar.Gordance with vith the Ventilation Filt&r TestFingProgramA e1r=P). the Vr=P-T.

ANG 1 A I AA 3i.7.12 1 J L I Amenament No.

AA

• I

Programs and Manuals 5.5 5.0 ADMINSTRATIVE CONTROLS 5.5 Programs and Manuals 5.5.10 Secondary Water Chemistry This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables;

b. Identification of the procedures used to measure the values of the critical variables;

c. Identification of process sampling points;

d. Procedures for the recording and management of data;

e. Procedures defining corrective actions for all off control point chemistry conditions; and

f. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events required to initiate corrective action.

5.5.11 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safeguards (ES) ventilation systems filters at the frequencies specified in Regulatory Guide 1.52, Revision 2. The VFTP is applicable to the Penetration Room Ventilation System (PRVS), the-Fuel Handan, Area Vcntilation Syst**m(FHAV9), and the Control Room Emergency Ventilation System (CREVS).

a. Demonstrate that an inplace cold DOP test of the high efficiency particulate (HEPA) filters shows:

1. > 99% DOP removal for the PRVS when tested at the system design flowrate of 1800 scfm +/- 10%0nd the FHA.VS when tested *tthe .systm design fiw,, te ,fm!+/-

of 39000 10%0o; and

2. k 99.95% DOP removal for the CREVS when tested in accordance with Regulatory Guide 1.52, Revision 2, at the system design flowrate of 2000 cfm +/- 10%.

ANO-1 5-0-20 Amendment No. 246,

Programs and Manuals 5.5 5.0 ADMINSTRATIVE CONTROLS 5.5 Programs and Manuals

b. Demonstrate that an inplace halogenated hydrocarbon test of the charcoal adsorbers shows:

1. > 99% halogenated hydrocarbon removal for the PRVS when tested at the system design fiowrate of 1800 cfm +/- 10%-aAd FHWAYS- when tested at the system design flowrate of 30000 cfm; h--10%; and

2. ý: 99.95% halogenated hydrocarbon removal for the CREVS when tested in accordance with Regulatory Guide 1.52, Revision 2, at the system design flowrate of 2000 cfm +/- 10%.

c. Demonstrate that a laboratory test of a sample of the charcoal adsorber meets the laboratory testing criteria of ASTM D3803-1989 when tested at 30°C and 95% relative humidity for a methyl iodide penetration of:

1. < 5% for the PRVS;

2. <5% for the FH.AM.S; and

32. when obtained as described in Regulatory Guide 1.52, Revision 2, for CREVS

i. < 2.5% for 2 inch charcoal adsorber beds; and ii. < 0.5% for 4 inch charcoal adsorber beds.

d. Demonstrate for the PRVS, FHAVS, nd CREVS, that the pressure drop across the combined HEPA filters, other filters in the system, and the charcoal adsorbers is < 6 inches of water when tested at the following system design flowrates +/- 10%:

PRVS 1800 cfm FHAVS 39900 -t CREVS 2000 cfm The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

ANO-1 5-0-21 Amendment No. 246,

Attachment 3 OCAN040701 ANO-2 Proposed Technical Specification Changes (mark-up)

REFUELING OPERATIONS SPENT FUEL POOL WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.10 At least 23 feet of water shall be maintained over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: Whenever irradiated fuel assemblies are in the spent fuel pool.

ACTION:

With the requirement of the specification not satisfied, suspend all movement of fuel assemblies and crane operations with loads in the spent fuel pool areas and restore the water level to within its limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.10 The water level in the spent fuel pool shall be determined to be at least its minimum required depth at least once per 7 days when irradiated fuel assemblies are in the spent fuel pool.

ARKANSAS - UNIT 2 314 9-11 Next Page is 3/4 9-14 I

REFUELING OPER-AXTIONIS FUEL H.ANDLING AREA V.ENT- LA.TION SYSTEM LIMITING CONDATION FOR OPERATION 3.0.11 The fuel handling area ventilation system shall be operating and discharging through the HEPA filters and charcoal aderbefr-.

.A.P.PLICr-.ABILITY: V r IF~diated fuel Is bcing moved in the ctorage pool and during crane operation with loads oVer the Storage pool.

AGT4GN-sa. With the Ael handling area ventilation system not operating, suspen;d all operations involving movrement o-f fuel within the spent fuel pool oFrcrane operation with loads-over the spent fuel pool until the fuel handling area ventilation system ie restored to ope~aiR I gl

b. I The evisions et 1pewirncaaon  ; are not appViGolie.

SURVEl I L.1-NCE REQUI-REMENTS 4.0.11.1 The fuel hanidling area ventilation system shall be determined to be inl operation and disc~harging through the HEMPA filters and-caca dobr at least once per 4.9.11.2 The fu-el h:ndliing a:rea ventilation sytem shall be demontrated OPERA.BLE when irradfiated-fuel irb in t.heA s-tor-age pool by peforming the required-fuel ha-ndlinRg filtcr testing in a~mccrdance with the Ventilation Fmilter Testing Program e/FT-P).

ARKAlNSAS UNIT 2 314 9_12 Amendment No. 13, 255*,

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ADMINISTRATIVE CONTROLS 6.5.11 Ventilation Filter Testinq Pro-gram (VFTP)

A program shall be established to implement the following required testing of Engineered Safeguards (ES) ventilation systems filters at the frequencies specified in Regulatory Guide 1.52, Revision 2. The VFTP is applicable to the Fuel- Hand!ing Area Ventilation Systm (FHAS) and the Control Room Emergency Ventilation System (CREVS).

a. Demonstrate that an inplace cold DOP test of the high efficiency particulate (HEPA) filters shows.

1. ý!00% DOP removal for the FHAYS when testcd at thc system deig fl,.'.rate of 39,700 cfm +/- 10%; and 2.-2 99.95% DOP removal for the CREVS when tested in accordance with Regulatory Guide 1.52, Revision 2, at the system design flowrate 2000 cfm +/- 10%.

b. Demonstrate that an inplace halogenated hydrocarbon test of the charcoal adsorbers shows_-*

1. 90.05% halogenated hydFroarbon remo'.al for the FHAVS when tccted at the system design flow rate of 30,700 Gfm +/- 10%; n 2----> 99.95% halogenated hydrocarbon removal for the CREVS when tested in accordance with Regulatory Guide 1.52, Revision 2, at the system design flow rate of 2000 cfm +/- 10%.

c. Demonstrate that a laboratory test of a sample of the charcoal adsorber meets the laboratory testing criteria of ASTM D3803-1989 when tested at 300C and 95% relative humidity for a methyl iodide penetration ot-

1. 45%Ifo the FHAVS;: and 2.-when obtained as described in Regulatory Guide 1.52, Revision 2, for CREVS

11. < 2.5% for 2 inch charcoal adsorber beds; and 4i2. < 0.5% for 4 inch charcoal adsorber beds.

d. Demonstrate for the FIAV8 and CREVS, that the pressure drop across the combined HEPA filters, other filters in the system, and charcoal adsorbers is

< 6 inches of water when tested at the following system design flowrates

+/- 10%.

FI-RV.$1 39,700 dm CREVS 2,000 cfm The provision of SR 4.0.2 and SR 4.0.3 are applicable to the VFTP test frequencies.

ARKANSAS - UNIT 2 6-15 Amendment No. 266,

Attachment 4 OCAN040701 List of Regulatory Commitments to OCAN040701 Page I of I List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Reguired)

The requirements to maintain the ANO-1 and x Within 60 ANO-2 FHAVS will be relocated to the ANO-1 and days of ANO-2 Technical Requirements Manual (TRM). approval