ML073330005
| ML073330005 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/04/2008 |
| From: | Wang A NRC/NRR/ADRO/DORL/LPLIV |
| To: | Mitchell T Entergy Operations |
| Wang, A B, NRR/DORL/LPLIV, 415-1445 | |
| Shared Package | |
| ML073330004 | List: |
| References | |
| TAC MD5379, TAC MD5380 | |
| Download: ML073330005 (16) | |
Text
February 4, 2008 Mr. Timothy G. Mitchell Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S. R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: RELOCATION OF THE FUEL HANDLING AREA VENTILATION SYSTEM AND ASSOCIATED FILTER TESTING PROGRAM REQUIREMENTS TO THE TECHNICAL REQUIREMENTS MANUALS (TAC NOS. MD5379 AND MD5380)
Dear Mr. Mitchell:
The Commission has issued the enclosed Amendment No. 231 to Renewed Facility Operating License No. DPR-51 and Amendment No. 274 to Renewed Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit 1 (ANO-1) and Unit 2 (ANO-2), respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated April 24, 2007, as supplemented by letter dated August 2, 2007, and electronic mail dated January 8, 2008.
The amendments relocate the Fuel Handling Area Ventilation System and associated Ventilation Filter Testing Program requirements that are included in the ANO-1 TS 3.7.12 and TS 5.5.11 and the ANO-2 TS 3.9.11 and TS 6.5.11, to the unit-specific Technical Requirements Manuals (TRMs). The TRMs are licensee-controlled documents which are controlled under Title 10 of the Code of Federal Regulations, Section 50.59, Changes, tests, and experiments.
A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368
Enclosures:
- 1. Amendment No. 231 to DPR-51
- 2. Amendment No. 274 to NPF-6
- 3. Safety Evaluation cc w/encls: See next page
February 4, 2008 Mr. Timothy G. Mitchell Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S. R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: RELOCATION OF THE FUEL HANDLING AREA VENTILATION SYSTEM AND ASSOCIATED FILTER TESTING PROGRAM REQUIREMENTS TO THE TECHNICAL REQUIREMENTS MANUALS (TAC NOS. MD5379 AND MD5380)
Dear Mr. Mitchell:
The Commission has issued the enclosed Amendment No. 231 to Renewed Facility Operating License No. DPR-51 and Amendment No. 274 to Renewed Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit 1 (ANO-1) and Unit 2 (ANO-2), respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated April 24, 2007, as supplemented by letter dated August 2, 2007, and electronic mail dated January 8, 2008.
The amendments relocate the Fuel Handling Area Ventilation System and associated Ventilation Filter Testing Program requirements that are included in the ANO-1 TS 3.7.12 and TS 5.5.11 and the ANO-2 TS 3.9.11 and TS 6.5.11, to the unit-specific Technical Requirements Manuals (TRMs). The TRMs are licensee-controlled documents which are controlled under Title 10 of the Code of Federal Regulations, Section 50.59, Changes, tests, and experiments.
A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368
Enclosures:
- 1. Amendment No. 231 to DPR-51
- 2. Amendment No. 274 to NPF-6
- 3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC LPLIV RF RidsAcrsAcnwMailCenter RidsNrrDirsItsb RidsNrrDorlDpr RidsNrrDorlLpl4 RidsNrrLAJBurkhardt RidsNrrPMAWang RidsOgcRp RidsRgn4MailCenter ERobinson, NRR/DRA/AADB ABoatright, NRR/DRA/AADB GHill, OIS (4)
ADAMS Accession Nos. Pkg ML073330004 (Amendment/License ML073330005, TS Pgs ML073330006)
(*)SE input memo
(**) See previous concurrence OFFICE NRR/LPL4/PM NRR/LPL4/LA DRA/AADB/BC DIRS/ITSB/BC OGC - NLO NRR/LPL4/BC NAME AWang (**)
JBurkhardt (**)
MHart (*)
TKobetz GWaig JBiggins (**)
THiltz DATE 1/8/08 1/8/08 10/04/07 2/1/08 1/23/08 2/4/08 OFFICIAL AGENCY RECORD
Arkansas Nuclear One (November 2007) cc:
Senior Vice President Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President
& Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Vice President, Operations Support Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Site Vice President Entergy Operations, Inc.
Arkansas Nuclear One 1448 S.R. 333 Russellville, AR 72802 General Manager Plant Operations Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Director, Nuclear Safety & Licensing Entergy Services, Inc.
440 Hamilton Avenue White Plains, NY 10601 Director, Nuclear Safety Assurance Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Senior Manager, Nuclear Safety
& Licensing Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298 Manager, Licensing Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Section Chief, Division of Health Radiation Control Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Section Chief, Division of Health Emergency Management Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Pope County Judge Pope County Courthouse 100 W. Main Street Russellville, AR 72801 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064
ENTERGY OPERATIONS, INC.
DOCKET NO. 50-313 ARKANSAS NUCLEAR ONE, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 231 Renewed License No. DPR-51
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Entergy Operations, Inc. (the licensee), dated April 24, 2007, as supplemented by letter dated August 2, 2007, and electronic mail dated January 8, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-51 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 231, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License No. DPR-51 and Technical Specifications Date of Issuance: February 4, 2008
ATTACHMENT TO LICENSE AMENDMENT NO. 231 RENEWED FACILITY OPERATING LICENSE NO. DPR-51 DOCKET NO. 50-313 Replace the following pages of the Renewed Facility Operating License No. DPR-51 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Operating License REMOVE INSERT 3
3 Technical Specifications REMOVE INSERT 3.7.12-1 3.8.10-1 3.8.10-1 5-0-20 5-0-20 5-0-21 5-0-21
ENTERGY OPERATIONS, INC.
DOCKET NO. 50-368 ARKANSAS NUCLEAR ONE, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 274 Renewed License No. NPF-6
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Entergy Operations, Inc. (the licensee),
dated April 24, 2007, as supplemented by letter dated August 2, 2007, and electronic mail dated January 8, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-6 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 274, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License No. NPF-6 and Technical Specifications Date of Issuance: February 4, 2008
ATTACHMENT TO LICENSE AMENDMENT NO. 274 RENEWED FACILITY OPERATING LICENSE NO. NPF-6 DOCKET NO. 50-368 Replace the following pages of the Renewed Facility Operating License No. NPF-6 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Operating License REMOVE INSERT 3
3 Technical Specifications REMOVE INSERT 3/4 9-11 3/4 9-11 3/4 9-12 6-15 6-15
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 231 AND 274 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-51 AND NPF-6 ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT NOS. 1 AND 2 DOCKET NOS. 50-313 AND 50-368
1.0 INTRODUCTION
By application dated April 24, 2007, as supplemented by letter dated August 2, 2007, and electronic mail dated January 8, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML071220178, ML072290108, and ML080080471, respectively), Entergy Operations, Inc. (the licensee), requested changes to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit 1 (ANO-1) and Unit 2 (ANO-2). The supplements dated August 2, 2007, and January 8, 2008, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on June 5, 2007 (72 FR 31098).
The proposed changes would relocate the Fuel Handling Area Ventilation System (FHAVS) and associated Ventilation Filter Testing Program (VFTP) requirements that are included in the ANO-1 TS 3.7.12 and TS 5.5.11 and the ANO-2 TS 3.9.11 and TS 6.5.11 to a licensee-controlled document, the unit-specific Technical Requirements Manuals (TRMs). The TRMs are licensee-controlled documents which are controlled under Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 59, Changes, tests, and experiments.
2.0 REGULATORY EVALUATION
The U.S. Nuclear Regulatory Commission (NRC) regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36. This regulation requires that the TSs include items in five specific categories. These categories include: 1) safety limits, limiting safety system settings and limiting control settings, 2) limiting conditions for operation (LCOs), 3) surveillance requirements, 4) design features, and 5) administrative controls. However, the regulation does not specify the particular TSs to be included in a plants license.
Additionally, 10 CFR 50.36(d)(2)(ii) sets forth four criteria to be used in determining whether an LCO is required to be included in the TSs. These criteria are as follows:
- 1.
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
- 2.
A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident (DBA) or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier.
- 3.
A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
- 4.
A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
Existing LCOs and related surveillances included as TSs requirements which satisfy any of the criteria stated above must be retained in the TSs. Those TSs requirements which do not satisfy these criteria may be relocated to other licensee-controlled documents.
This safety evaluation addresses the impact of the proposed changes on previously analyzed DBA radiological consequences and the acceptability of the revised analysis results. The regulatory requirements for which the NRC staff based its acceptance are the accident dose guidelines in 10 CFR 100.11, as supplemented by accident-specific criteria in Section 15 of the Standard Review Plan (SRP), and 10 CFR Part 50, Appendix A, General Design Criterion 19 (GDC 19), AControl Room,@ as supplemented by Section 6.4 of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants." Except where the licensee proposed a suitable alternative, the NRC staff used the regulatory guidance provided in Regulatory Guide (RG) 1.195, AMethods and Assumptions for Evaluating Design Basis Accidents at Light-Water Nuclear Power Reactors,@ in performing this review. Because the only DBA impacted by the proposed TS changes is the fuel handling accident (FHA), the NRC staff evaluated the licensees analysis against the accident-specific dose acceptance criteria for offsite doses in SRP 15.7.4, Radiological Consequences of Fuel Handling Accidents. These dose acceptance criteria are that the whole-body and thyroid doses at the exclusion area boundary (EAB) for the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the accident are acceptable if they are well within (25 percent of) the exposure guideline in 10 CFR 100.11, i.e., 75 roentgen equivalent man (rem) for the thyroid and 6 rem for whole-body exposure. The regulatory dose criterion given in GDC 19 for the control room is 5 rem whole body or its equivalent to any part of the body for the duration of the accident. SRP 6.4, Control Room Habitability System, defines the equivalency as 30 rem for the thyroid and 30 rem for the skin from beta radiation exposure.
The NRC staff also considered relevant information in the ANO-1 and ANO-2 Updated Final Safety Analysis Report (UFSAR) and TSs, as well as, consideration for any applicable supporting documentation the licensee may have provided.
3.0 TECHNICAL EVALUATION
The ANO-1 and ANO-2 FHAVS maintains a suitable environment for equipment operation and personnel access in the fuel handling area. The systems were primarily designed to filter any gaseous radioactivity that may occur during normal or accident conditions, i.e., an FHA. On this basis, the systems are currently classified and designed as an engineered safety features (ESF) air cleanup system.
TS 3.7.12 and TS 3.9.11, for ANO-1 and ANO-2, respectively, include requirements to maintain the FHAVS during movement of irradiated fuel assemblies in the fuel handling area. These TSs also include filter testing requirements for the FHAVS in the VFTP (TS 5.5.11 and TS 6.5.11, for ANO-1 and ANO-2, respectively). The proposed relocation of the FHAVS from the TSs to the TRMs, will still require that the ANO-1 and ANO-2 FHAVS filtration testing be performed consistent with the guidance in RG 1.140, Revision 1, dated October 1979, "Design, Testing, and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants." RG 1.140, Revision 1, requires filter testing once per 18 months, which is 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. At this time, no plant modifications are planned to remove the ANO-1 or ANO-2 FHAVS.
3.1 Radiological Consequences The NRC staff reviewed the regulatory and technical analyses, as related to the radiological consequences of DBAs, performed by the licensee in support of its proposed license amendment. Information regarding these analyses was provided in Sections 4 and 5 of its submittal. The NRC staff reviewed the assumptions, input, and methods used by the licensee to assess the impact of the proposed license amendment. The findings of this safety evaluation input are based on the descriptions of the licensee=s analyses and other supporting information docketed by the licensee.
The license amendment request (LAR) proposes to relocate the ANO-1 and ANO-2 TSs that require the FHAVS to be operable and in operation during movement of irradiated fuel assemblies in the fuel handling area. In addition, the LAR for ANO-1 and ANO-2 proposes to relocate the associated surveillance requirements as specified in TS 5.5.11 (ANO-1) and TS 6.5.11 (ANO-2) requiring the licensee to perform required FHAVS filter testing in accordance with the VFTP at frequencies specified in RG 1.52, Revision 2, " Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants."
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. ANO-1 and ANO-2 both contain SFP ventilation exhaust fans (VEF-14A/B and 2VEF-14A/B), each consisting 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 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 percent of particles 0.3 m (micrometers) and larger, and the charcoal filter is used to trap radioactive particles, specifically methyl iodide, also referred to as organic iodine. Further, a high differential pressure alarm across the three-element filter exists for each of the SFP ventilation exhaust fans, which is annunciated in the control room of the specific unit. In addition, the discharge of VEF-14A/B and 2VEF-14A/B are monitored for radioactivity by a Super Particulate Iodine and Noble Gas Monitor (SPING3 for ANO-1 and SPING7 for ANO-2) which are part of the Radiological Dose Assessment Computer System.
In support of the proposed license amendments, previous amendments were issued permitting the containment building to be open during the movement of irradiated fuel. ANO-1 License Amendment 184 (dated September 20, 1996) and ANO-2 License Amendment 166 (dated September 28, 1995), were supported by licensee analysis of the radiological consequences of the design-basis FHA inside the reactor building without credit for containment isolation, holdup within the containment or filtration of the postulated radiological release from the FHA. For the radiological analysis of the FHA inside the reactor building in support of the above TS changes for this subject LAR, the licensee used the same assumptions as were reviewed and found acceptable by the staff in association with Amendment 184 and Amendment 166, for ANO-1 and ANO-2, respectively.
License amendments and TSs changes to permit the containment equipment hatch to be open during the handling of irradiated fuel in containment and core alterations provided that the capability for quick closure is maintained were subsequently approved by the NRC, by letter dated April 16, 1999, in Amendment 195 and Amendment 203 for ANO-1 and ANO-2, respectively. The current licensing and design basis for ANO-1 and ANO-2 includes FHA analysis assuming an unmitigated release from the containment building with the hatch open.
The NRC staffs review for the previous amendments discussed above found that the licensee used analysis methods consistent with the guidance in RG 1.195 and that the licensees analysis shows that ANO-1 and ANO-2 continue to meet the regulatory dose requirements of Part 100 and GDC 19, as well as the SRP accident-specific dose acceptance criteria, without mitigation for the FHA.
During the NRC staffs review of the proposed LAR, it was confirmed that there are no non-safety systems credited in the licensees previously approved analysis of the postulated design-basis FHA in the SFP area. By supplemental letter dated August 2, 2007, in response to a request for additional information (RAI), the licensee stated that the FHAVS is not credited in the licensees FHA analysis and is not needed to perform a safety function required to mitigate the consequences of an accident. In order to support the licensees determination that the current licensing-basis FHA radiological consequences analysis remain bounding for the proposed TS changes, the licensee has determined that activity released from the Fuel Handling Building (FHB) and SFP area is directed to a location on the containment building wall that is well-characterized by the location of the current design-basis containment hatch release point.
The NRC staff confirmed that the ANO-1 SFP and fuel handling area are ventilated by fans that are mounted on the roof of the ANO-1 auxiliary building. These fans exhaust through a duct that is mounted on the outside of the ANO-1 reactor building wall. The effluents are then directed to a release point at elevation 533 feet 6 inches at the top of the ANO-1 reactor building. Similarly, the ventilation air from the ANO-2 fuel handling floor radwaste area is exhausted out a containment flute on the outer wall of the ANO-2 containment at elevation 533 feet 3 inches.
This clearly indicates that since both units exhaust activity releases from the ducts located at the top of their respective containment structures, it was determined that the atmospheric dispersion of a release due to an FHA would be the same whether the release is from the containment or from the fuel handling area. Therefore, it was verified by the NRC review that the atmospheric dispersion of activity associated with the current design-basis FHA containment hatch release point, bounds the atmospheric dispersion of activity expected from the SFP area and FHB. The licensee also provided information to support this finding in its August 2, 2007, RAI response letter.
Based on the considerations discussed above, and the information provided by the licensee regarding the FHA, the NRC staff finds reasonable assurance that the TS changes proposed by the licensee to ANO-1 and ANO-2 are already bounded by the licensees current licensing-basis FHA dose analysis. Therefore, both ANO units continue to meet the guidelines of 10 CFR Part 100 and the dose criteria of 10 CFR Part 50, Appendix A, GDC 19. Therefore, the NRC staff finds that the proposed changes to the ANO-1 and ANO-2 TSs are acceptable with regard to the radiological consequences of design-basis analyses.
As described above, the NRC staff reviewed the assumptions, input, and methods used by the licensee to assess the radiological consequences of the postulated DBA analyses with the proposed TS changes. The NRC staff finds that the licensee used analysis methods and assumptions consistent with the conservative regulatory requirements and guidance identified in Section 2.0. The NRC staff compared the doses estimated by the licensee to the applicable criteria identified in Section 2.0. The NRC staff also concludes that the licensees estimates of the control room and EAB doses will comply with these criteria. The NRC staff further finds reasonable assurance that ANO-1 and ANO-2, as modified by this LAR, will continue to provide sufficient safety margins, with adequate defense-in-depth, to address unanticipated events and to compensate for uncertainties in accident progression, analysis assumptions, and input parameters. Therefore, 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 during an FHA. On this basis, the classification of the system as an ESF air cleanup system may be downgraded. Therefore, the proposed license amendment is acceptable with respect to the radiological consequences of DBAs.
3.2 10 CFR 50.36 Review 10 CFR 50.36, Technical Specifications, lists four criterion that require the establishment of a LCO with the basis for the ANO-1 and ANO-2 FHAVS:
- 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.
- 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 DBA or transient analysis associated with the integrity of a fission product barrier.
- 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 an FHA are well within the limits given in 10 CFR 100. Therefore, the FHAVS is not needed for the successful mitigation of a FHA.
- 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 an FHA are well within the limits given in 10 CFR 100.
The offsite and control room dose consequences of an FHA in the respective unit's SFP area have been performed for both units without FHAVS filtration. The NRC staff has concluded that the offsite dose consequences are well within the regulatory limits without credit for FHAVS filtration and, therefore, the FHAVS does not perform a safety function required to mitigate the consequences of an accident. The NRC staff has reviewed the licensees analysis for the FHAVS against the four criteria of 10 CFR 50.36. The NRC staff agrees that the FHAVS does not meet any of the criteria of 10 CFR 50.36 for inclusion in TSs and, therefore, the FHAVS TSs maybe relocated to the TRMs. The TRMs are licensee-controlled documents, which are controlled under 10 CFR 50.59, Changes, tests, and experiments. In addition, the proposed relocation of the FHAVS from the TSs to the TRMs will still require that the ANO-1 and ANO-2 FHAVS filtration testing be performed consistent with the guidance in RG 1.140, Revision 1.
RG 1.140, Revision 1, requires filter testing once every 18 months, which is 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.
4.0 REGULATORY COMMITMENTS The licensee has made the following regulatory commitment with respect to this LAR:
The requirements to maintain the ANO-1 and ANO-2 FHAVS will be relocated to the ANO-1 and ANO-2 Technical Requirements Manual (TRM).
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Arkansas State official was notified of the proposed issuance of the amendments. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published on June 5, 2007 (72 FR 31098). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: E. Robinson A. Wang Date: February 4, 2008