ML112650269

Licensee Handouts for 10/05/2011 Presubmittal Meeting

ML112650269
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/22/2011
From:	Entergy Operations
To:	Kalyanam N Plant Licensing Branch IV
Kalyanam N, NRR/DLPM, 415-1480
References
TAC ME6887
Download: ML112650269 (20)

Text

Arkansas Nuclear One - Unit 2 October 5, 2011 Pre-Submittal Meeting Technical Specification (TS) Revisions Associated with:

Revised Fuel Handling Accident Analysis Adoption of TSTF TSTF-5151 Adoption of TSTF-272 Adoption of TSTF-286 Adoption of TSTF-471 Relocation/Deletion of non-ITS Shutdown TSs

Deletion /

Relocation of Revised FHA Related Non-ITS Analysis TSTF-51 TSTF-272 TSTF-286 TSTF-471 Specifications TS 3.1.1.3 RCS Dilution Flow Rate DELETED TS 3.3.3.1 Rad Monitoring TS 3.4.1.2 RCS Loops - Mode 3 TS 3.4.1.3 RCS Loops - Modes 4/5 TS 3.7.6.1 CREVS TS 3.8.1.2 AC Power - Shutdown TS 3.8.2.2 AC Dist. - Shutdown TS 3.8.2.4 3 8 2 4 DC Power - Shutdown TS 3.9.1 Boron Conc. - Mode 6 TS 3.9.2 Source Range Flux Inst.

TS 3.9.3.a Decay Time RELOCATED TS 3.9.4 Containment Penetrations TS 3.9.5 Refueling Communications RELOCATED TS 3.9.6 Refueling Bridge RELOCATED TS 3.9.7 Crane Loads over SFP RELOCATED TS 3.9.8.1 SDC Loops TS 3.9.8.2 SDC Loops - Low Level TS 3.9.9 Refueling Water Level

Fuel Handling Accident (FHA)

ANO-2 adoption of Alternate Source Terms provided a revised FHA which will require changes to fuel handling related TSs. Previously, only the dropped fuel assembly was considered to rupture. The revised analysis assumes all fuel rods in the dropped and the impacted assembly rupture (reviewed and accepted by NRC in AST SE for ANO-2).

Before: during movement of irradiate fuel After: during movement of irradiated fuel assemblies or movement of any fuel assembly over irradiated fuel assemblies assemblies Affected TSs:

3.3.3.1 - Containment Purge and Control Room Radiation Monitoring Instrumentation (administrative changes also made to enhance TS usability) 3.7.6.1 - Control Room Emergency Ventilation (CREVS) 3.8.1.2 - AC Sources - Shutdown 3.8.2.2 - AC Distribution - Shutdown 3.8.2.4 - DC Sources/Distribution - Shutdown 3.9.4 - Containment Penetrations (shutdown)

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent control room emergency ventilation and air conditioning systems shall be OPERABLE. (Note 1)

APPLICABILITY: MODES 1 1, 2 2, 3 3, 4 4, or during movementhandling of irradiated fuel assemblies or movement of any fuel assembly over irradiated fuel assemblies.

ACTION:

MODES 1, 2, 3, and 4

a. With one control room emergency air conditioning system (CREACS) inoperable, restore the inoperable system to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

TSTF-51 Revise Requirements During Handling Irradiated Fuel / Core Alterations Removes the Core Alterations term from the TSs since only a FHA could result in doses that approach limits and due to minimal (if any) reactivity affect of other manipulations. Also incorporates the term recently irradiated fuel for various TS requirements. The latter permits the licensee to control equipment availability and establish appropriate compensatory measures provided fuel decay is sufficient to limit offsite release to within regulatory requirements upon an FHA.

Before: during movement of irradiate fuel or Core Alterations After: during during movement of recently irradiated fuel assemblies or movement of any fuel assembly over recently irradiated fuel assemblies Affected TSs:

3.3.3.1 - Containment Purge and Control Room Radiation Monitoring Instrumentation 3.7.6.1 - Control Room Emergency Ventilation (CREVS) 3.8.1.2 - AC Sources - Shutdown 3.8.2.2 - AC Distribution - Shutdown 3.8.2.4 - DC Sources/Distribution - Shutdown 3.9.4 - Containment Penetrations (shutdown) 3.9.9 - Reactor Vessel Water Level

TABLE 3.3-6 (Continued)

TABLE NOTATION ACTION 13 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 16 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, complete the following:

a. If performing CORE ALTERATIONS or moving recently irradiated fuel assemblies or moving any fuel assembly over recently irradiated fuel assemblies within the Containmentreactor Bbuilding, secure the Ccontainment Ppurge Ssystem or suspend CORE ALTERATIONS and movement of recently irradiated fuel assemblies or movement of any fuel assembly over recently irradiated fuel assemblies within the Containmentreactor Bbuilding.

b. If a Ccontainment PURGE is in progress, secure the Ccontainment Ppurge Ssystem.

c. If continuously ventilating, verify the SPING monitor operable or perform the applicable ACTION(s) of the Offsite Dose Calculation Manual, Appendix 1, Limitation 2.2.1; otherwise, secure the Containment Purge System.

TSTF-272 Operations Involving Positive Reactivity Additions This TSTF corrected a deficiency in the Refueling Boron TSs. Previously, refueling boron was applicable to the RCS in Mode 6. However, the TS did not specifically address the refueling canal when flooded and connected to the RCS (i.e., reactor vessel head removed). The TSTF added a Note to the associated TS applicability to ensure refueling canal boron was equally controlled and limited when connected to the RCS.

Before: Mode 6 After: Note is added to the Mode 6 Applicability which states Only applicable to the refueling canal when connected to the RCS.

Affected TSs:

3.9.1 - Boron Concentration (Mode 6)

3/4.9 REFUELING OPERATIONS BORON CONCENTRATION LIMITING CONDITION FOR OPERATION 3.9.1 With the reactor vessel head unbolted or removed, Tthe boron concentration of the reactor coolant and the refueling canal shall be maintained uniform and sufficient to ensure that the more restrictive of following reactivity conditions is met:

APPLICABILITY: MODE 6*.

• The reactor shall be maintained in MODE 6 when the reactor vessel head is unbolted or removedOnly applicable to the refueling canal when connected to the RCS.

TSTF-286 Refueling Boron Concentration Clarification The purpose of the TSTF was to permit operators to continue to control RCS inventory and temperature while maintaining positive control of core reactivity.

Therefore, most related TSs removed requirements that prevented positive reactivity addition or reduction in boron concentration in lieu of a more generic requirement that ensured SDM would be maintained during RCS inventory or temperature adjustments.

Before: suspend operations involving a reduction in boron concentration After: suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM Affected TSs:

3.4.1.2 - Reactor Coolant Loops (Mode 3) 3.4.1.3 - Reactor Coolant Loops (Modes 4 and 5) 3.8.1.2 - AC Sources - Shutdown 3.8.2.2 - AC Distribution - Shutdown 3.8.2.4 - DC Sources/Distribution - Shutdown 3.9.2 - Source Range Flux Instrumentation 3.9.8.1 - Shutdown Cooling Loops - Mode 6 3.9.8.2 - Shutdown Cooling Loops - Mode 6 with water level < 23 feet

REFUELING OPERATIONS INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.9.2 As a minimum, two source range neutron flux monitors shall be operating, each with continuous visual indication in the control room and one with audible indication in the containment and control room.

APPLICABILITY: MODE 6 6.

ACTION:

a. With one of the above required monitors inoperable, immediately suspend all positive reactivity additions and operations involving thatCORE ALTERATIONS or would cause introduction of coolant into the RCS withpositive reactivity boron concentration less than required to meet the boron concentration of LCO 3.9.1changes.

b. With both of the above required monitors inoperable, determine the boron concentration of the reactor coolant system at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

TSTF-471 Eliminate use of term Core Alterations in Actions and Notes This TSTF corrected an oversight related to implementation of TSTF-51.

TSTF-471 was written to eliminate remaining references to Core Alterations.

Before: Core Alterations (or movement of CEAs)

After: during movement of irradiated fuel assemblies or movement of any fuel assembly over irradiated fuel assemblies Affected TSs:

Definitions - Core Alterations 3.8.1.2 - AC Sources - Shutdown 3.8.2.2 - AC Distribution - Shutdown 3.8.2.4 - DC Sources/Distribution - Shutdown 3.9.1 - Boron Concentration 3.9.2 - Source Range Flux Instrumentation

3/4.9 REFUELING OPERATIONS BORON CONCENTRATION LIMITING CONDITION FOR OPERATION 3.9.1 With the reactor vessel head unbolted or removed, Tthe boron concentration of the reactor coolant and the refueling canal shall be maintained uniform and sufficient to ensure that the more restrictive of following reactivity conditions is met:

APPLICABILITY: MODE 6*.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes and initiate and continue boration at 40 gpm of 2500 ppm boric acid solution until Keff is reduced to 0.95 or the boron concentration is restored to 2500 ppm, whichever is the more restrictive. The provisions of Specification 3.0.3 are not applicable.

TS 3.1.1.3 Deletion TS 3.1.1.3 does not appear in the ITS. The intent is to ensure sufficient flow for adequate mixing in the RCS, but in reality could only be applicable when SDC is in service (RCPs have large flow rate). Therefore, one of the Surveillance Requirements in TS 3.4.1.3 is modified to ensure the 2000 gpm limit is verified when on SDC, and TS 3.1.1.3 is deleted.

Affected TSs:

3.1.1.3 - Boron Dilution - reduction in boron 3.4.1.3 - Reactor Coolant Loops (Modes 4 and 5)

REACTIVITY CONTROL SYSTEMS BORON DILUTION LIMITING CONDITION FOR OPERATION 3.1.1.3 The flow rate of reactor coolant through the reactor coolant system shall be 2000 gpm whenever a reduction in Reactor Coolant System boron concentration is being made.

APPLICABILITY: ALL MODES.

ACTION:

With the flow rate of reactor coolant through the reactor coolant system < 2000 gpm, immediately suspend all operations involving a reduction in boron concentration of the Reactor Coolant System.

SURVEILLANCE REQUIREMENTS 4.1.1.3 The flow rate of reactor coolant through the reactor coolant system shall be determined to be 2000 gpm within one hour prior to the start of and at least once per hour during a reduction in the Reactor Coolant System boron concentration by either:

a. Verifying at least one reactor coolant pump is in operation, or

b. Verifying that at least one low pressure safety injection pump or containment spray pump is in operation as a shutdown cooling pump and supplying 2000 gpm through the reactor coolant system.

REACTOR COOLANT SYSTEM SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.1.3 a. At least two of the coolant loops listed below shall be OPERABLE:

b. At least one of the above coolant loops shall be in operation.*

APPLICABILITY: Modes 4 and 5.

ACTION:

b. With no coolant loop in operation or with coolant flow rate < 2000 gpm, suspend all operations that would cause involving a reduction inintroduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.1 or LCO 3.1.1.2, as applicable, of the Reactor Coolant System and immediately initiate corrective action to return the required coolant loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.3.4 At least one coolant loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and, when relying on a shutdown cooling loop, flow rate shall be verified to be 2000 gpm.

TS Relocations The following specifications are no longer in the ITS and are relocated to the ANO-2 TRM. A copy of the new TRMs is included in the submittal.

Affected TSs:

3.9.3.a - Decay Time (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to movement of fuel) 3.9.5 - Communications (during movement of fuel) 3.9.6 - Refueling Machine Operability (during movement of fuel) 3.9.7 - Crane Travel - Spent Fuel Pool Building (loads over fuel)

REFUELING OPERATIONS DECAY TIME AND SPENT FUEL STORAGE LIMITING CONDITION FOR OPERATION 3.9.3.a The reactor shall be subcritical for at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

APPLICABILITY: During movement of irradiated fuel in the reactor pressure vessel.

ACTION:

With the reactor subcritical for less than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, suspend all operations involving movement of irradiated fuel in the reactor pressure vessel. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.3.a The reactor shall be determined to have been subcritical for at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> by verification of the date and time of subcriticality prior to movement of irradiated fuel in the reactor pressure vessel.

REFUELING OPERATIONS COMMUNICATIONS LIMITING CONDITION FOR OPERATION 3.9.5 Direct communications shall be maintained between the control room and personnel at the refueling station.

APPLICABILITY: During CORE ALTERATIONS.

ACTION:

When direct communications between the control room and personnel at the refueling station cannot be maintained, suspend all CORE ALTERATIONS. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.5 Direct communications between the control room and personnel at the refueling station shall be demonstrated within one hour prior to the start of and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS.

REFUELING OPERATIONS REFUELING MACHINE OPERABILITY LIMITING CONDITION FOR OPERATION 3.9.6 The refueling machine shall be used for movement of fuel assemblies and shall be OPERABLE with:

a. A minimum capacity of 3750 pounds,

b. An overload cut off limit of 100 pounds plus the combined weight of one fuel assembly, one CEA, and the grapple in the "fuel only" region, and

c. An overload cut off limit of 100 pounds plus the combined weight of one fuel assembly, one CEA, the grapple, and the hoist box in the "fuel plus hoist box" region.

g APPLICABILITY: During movement of CEAs or fuel assemblies within the reactor pressure vessel.

ACTION:

With the requirements for refueling machine OPERABILITY not satisfied, suspend its use from operations involving the movement of CEAs and fuel assemblies within the reactor pressure vessel. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.6 The refueling machine shall be demonstrated OPERABLE within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start of movement of fuel assemblies within the reactor pressure vessel by performing a load test of at least 3750 pounds and demonstrating automatic load cut offs when the crane loads exceed 100 pounds plus the applicable loads.

REFUELING OPERATIONS CRANE TRAVEL - SPENT FUEL POOL BUILDING LIMITING CONDITION FOR OPERATION 3.9.7 Loads in excess of 2000 pounds shall be prohibited from travel over fuel assemblies in the spent fuel pool.

APPLICABILITY: With fuel assemblies in the spent fuel pool.

ACTION:

With the requirements of the above specification not satisfied, place the crane load in a safe condition. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.7 The crane electrical power disconnect which prevents crane travel over the spent fuel pool shall be verified open under administrative control at least once per 7 days, or the crane travel interlock which prevents crane travel over the spent fuel pool shall be demonstrated OPERABLE within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to each use of the crane for lifting loads in excess of 2000 pounds.