ML19325E388

Application for Amends to Licenses DPR-51 & NPF-6,revising Tech Spec Table 3.5.1-1 to Include Operability Requirements for Reactor Vessel Level Monitoring Sys & Hot Leg Level Measurement Sys

ML19325E388
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/26/1989
From:	Tison Campbell ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19325E389	List: ML19325E388 ML19325E390
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM 0CAN108909, CAN108909, NUDOCS 8911060413
Download: ML19325E388 (7)

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Power & Ught Company 425 West C:pitol

• D P. o. Box 651

, , s Uttle Rock. Arkansas 72203 o Tel 501377 3525 T. O. Campbell v Pres dent 1^ October 26, 1989'

.9CAN198999

.U. S. Nuclear. Regulatory Commission Document Control Desk Mail Station P1-137 Washington,.DC 20555

Subject:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Additional ICC Technical Specifications Gentlemen:

NRC letter dated March 23,1989,(0CNA038925) transmitted the Safety Evaluation of the'AN0-1 and 2 Inadequate Core Cooling (ICC) instrumentation systems, which concluded that the ICC systems for both units are performing satisfactorily and meet.the design and operation requirements specified in NUREG-0737, Item II.F.2. In that letter the staff also requested that additional technical specifications be developed for the Reactor Vessel Level Monitoring Systems (RVLMSs) for both AN0 units and the Hot Leg Level Measurement System (HLLMS) for ANO-1, and provided guidance for their preparation. As requested

-by the NRC staff, this letter transmits our proposed technical specifications.

Technical specifications for the other portions of the ANO ICC instrumentation (subcooled margin monitors and core exit thermocouples) for both units have been submitted and approved previously.

In accordance with the above referenced NRC guidance, AP&L proposes that the operability requirements for the ANO-1 RVLMS and HLLMS be included in ANO-1 Technical . Specification Table 3.5.1-1 and the associated Surveillance Requirements in Table 4.1-1, and reflected in the appropriate Bases. The operability and surveillance requirements for the ANO-2 RVLMS are proposed to be included in Tables 3.3-10 and 4.3-10, respectively, of the ANO-2 Technical l' Specifications. Associated Special Report requirements are also proposed to be reflected in the appropriate location in Section 6 for each unit. The proposed changes are attached for your review and approval.

p Operability and surveillance requirements similar to those proposed for ANO-1 l and 2 were approved for TMI-1 (docket 50-289) by issuance of Amendment 147 dated December 13, 1988, and for San Onofre (dockets 50-361 and 50-362) p by issuance of Amendments 60 and 49 dated August 14, 1987, respectively.

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October 26, 1989 In accordance with 10CFR50.91(a)(1), and using the criteria in 10CFR50.92(c),

• AP&L has determined that the proposed change involves no significant hazards. consideration. Our basis for this determination is also attached for your review. The circumstances of the proposed change are neither exigent nor an emergency.

AP&L requests that the effective date for this change be 30 days after NRC i issuance of the amendment to allow for distribution and procedaral revisions necessary to implement this change. '

s-Very truly yours, WW-T. G. Camp 1 A

TGC:rbt Attachment cc: Mr. Robert Martin ,

U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Senior Resident Inspector Arkansas Nuclear One - ANO-1 & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Mr. C. Craig Harbuck NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-D-18 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Chester Poslusny l NRR Project Manager, Region IV/ANO-2 i U. S. Nuclear Regulatory Commission l NRR Mail Stop 13-D-18 l One White Flint North lL 11555 Rockville Pike l Rockville, Maryland 20852 1'

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L STATE OF ARKANSAS )  :

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. l I, T. Gene Campbell, being duly sworn, subscribe to and say that I am l 1

Vice President, Nuclear'for Arkansas Power & Light Company; that I have full  !

authority to execute this oath; that I have read the document numbered  ;

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SCAN 198989 and know the contents'thereof; and that to the best of my '

knowledge, information and belief, the statements in it are true. ,

T. G. Campb 1 -

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' SUBSCRIBED AND SWORN T0 before me, a Notary Public in and for the CountyandStateabovenamed,this${c u day of OcL6r . .

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PROPOSED TECHNICAL SPECIFICATION CHANGES l

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LICENSE AMENDMENT' REQUEST q IN THE MATTER OF AMENDING

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LICENSE.NO. DPR  !

4 LICENSE NO. NPF-6 ARKANSAS POWER &-LIGHT COMPANY d i

. ARKANSAS-NUCLEAR ONE, UNIT 1 ,

W NRKANSASNUCLEAR0NE, UNIT 2  :

DOCKET NO. 50-313

.7 DOCKET NO. 50-368 '!;

OCTOBER 17, 1989

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DESCRIPTION OF PROPOSED CHANGE AP&L proposes to add technical specifications for additional Inadequate Core 4 h Cooling (ICC) instrumentation, specifically the Reactor Vessel Level Monitoring Systems (RVLMS) for both ANO-1 and 2, and the Hot Leg Level Measurement System (HLLMS) for ANO-1, in accordance with NRC request.

AP&L proposes that the operability requirements for the ANO-1 RVLMS and HLLMS be included in ANO-1 Technical Specification Table 3.5.1-1 and the associated Surveillance Requirements in Table 4.1-1, and reflected in the appropriate Bases.

The operability and surveillance requirements for the ANO-2 RVLMS are proposed to be included in Tables 3.3-10 and 4.3-10, respectively, of the ANO-2 Technical Specifications. Special Report requirements associated with the proposed changes will also be reflected in the appropriate location of Section 6 (Administrative Controls) for each unit.

DISCUSSION ANO-1 Technical Specification 3.5.1, Operational Safety Instrumc0tation,

' delineates the conditions of the unit instrumentation and safety circuits necessary to assure reactor safety. Specifications 3.5.1.1 and 3.5.1.2, respectively, state that the operability requirements of Table 3.5.1-1, Columns 3'and 4 must be met, or operation shall be limited as specified in Column 5. AP&L proposes to add the operability requirements associated with the RVLHS and HLLMS as Table 3.5.1-1 Items 14 and 15, respectively, with the Column 5 action specified under Note 27. The associated surveillance requirements are to be added as Table 4.1-1 Items 63 and 64. The channel operability of the RVLMS is defined as a minimum of three sensors in the upper plenum region and two sensors in the dome region operable. The HLLMS is configured such that one channel is composed of one wide range (WR) transmitter for one hot leg and four narrow range (NR) transmitters for the other hot leg.

Each hot leg therefore has a WR and four NR transmitters associated with different safety channels, which provides a desired redundancy above that which would be provided if all transmitters associated with a hot leg were of the same channel. Therefore, the channel operability of the HLLMS is defined as a minimum of one WR and any two of the NR transmitters in the same channel operable. The action associated with a condition where fewer than the minimum number of channels are operable allows continued operation, but requires a Special Report to the NRC, outlining the cause of the inoperability and the plans and schedule for restoring the system to operable status, and also requires that both channels of the system be restored to operable at the next I scheduled refueling outage. This requirement for a Special Report will also l be reflected in Section 6.12.5.

ANO-2 Technical Specification 3/4.3.3.6, Post-Accident Instrumentation, provides i the operability and surveillance requirements for post-accident monitoring

( instrument channels. Specification 3.3.3.6(a) requires the minimum number of operable channels specified by Table 3.3-10, and the associated Surveillance

, Requirement 4.3.3.6 requires periodic demonstration of operability at l frequencies shown in Table 4.3-10. AP&L proposes to add the RVLMS operability I and surveillance requirements as Table 3.3-10 Itera 14, and Table 4.3-10 Item 14, respectively. The channel operability of the ANO-2 RVLMS is defined l as a minimum of two sensors in the upper plenum region and one sensor in the dome region operable. A note will be added to Table 3.3-10 Item 14 to show l

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that continued operation with less than the required number of operable channels is allowed, but requiring a Special Report to the NRC, outlining the

cause of the inoperability and the plans and schedule for restoring the system

, to operable status, and also requiring that both channels of the system be restored to operable at the next scheduled refueling outage. This requirement for a Special Report will also be reflected in Section 6.9.2.

BACKGROUND

[ By NRC " Order for Modification of License" dated December 10, 1982, AP&L was required to install specific RCS inventory tracking systems as part of the Inadequate Core Cooling (ICC) instrumentation systems in accordance with NUREG-0737, Item II.F.2. NRC Generic Letter 83-37 was subsequently issued on November 1, 1983 to provide guidance on technical specifications for this and other equipment, required by NUREG-0737. The ANO ICC instrumentation systems were evaluated and approved by issuance of NRC Safety Evaluation dated March 23, 1983. The systems consist of subcooled margin (SCM) monitors, core exit thermocouples (CETs), and Reactor Vessel Level Monitoring Systems (RVLMS),

for both ANO-1 and ANO-2, and a Hot Leg Level Measurement System (HLLMS) for ANO-1. The technical specifications for the SCM monitors and CETs for both units have been submitted and approved previously.

The function of the ICC instrumentation is to enhance the ability of the plant operator to diagnose the approach te, existence of, and recovery from ICC conditions. The specific instrumentation addressed by this proposed change also aids in tracking reactor coolant inventory. However, this instrumentation is not required by the accident analyses, nor to briag the plant to cold  ;

shutdown conditions. In the event that more than the mquired number of operable RVLMS sensors or HLLMS transmitters are inoperable, repairs may only be possible during the next refueling outage. This is because the RVLMS sensors are accessible only after the reactor missle shield and reactor vessel head are removed. It is therefore not feasible to repair a channel except during a refueling outage when the missle shield and reactor vessel head are removed to refuel the core. Similarly, HLLMS transmitters may only be .

accessible for repair when the reactor coolant system has been depressurized l and drained during a refueling outage. In the event that only one channel i is inoperable, it should be restored as soon as reasonably possible during )

a refueling outage. If both channels are inoperable, both must be restored i to operable status in the next scheduled refueling outage. In the event that both channels of the RVLMS and HLLMS are inoperable, existing plant instruments and operator training will be used as an alternate method of monitoring reactor core cooling and potential ICC conditions. The reactor coolant inventory tracking instrumentation may be a useful information system if available, but it will not cause an adverse impact if it is not operable. The required actions discussed above therefore provide the appropriate level of emphasis for an information system; i.e., to allow continued plant operation and not to force an unnecessary shutdown.

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DESCRIPTION OF PROPOSED NO SIGNIFICANT HAZARDS DETERMINATION In accordance with 10CFR50.92, AP&L has evaluated whether the proposed change i involves a significant safety hazards consideration. AP&L has concluded that the proposed changes to incorporate operability and surveillance requirements i

for the reactor coolant inventory tracking portions of the ICC system do not n involve a significant hazards consideration because the operation of Arkansas Nuclear One, Units 1 and 2 in accordance with this change would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

. The reactor coolant inventory tracking portion of the ICC instrumentation is l- used for operator information only. There are no safety system actuations or any specific operator actions taken solely on indications from the

instrumentation addressed by this proposed change. Therefore, the accident mitigation features of the plant are not affected by the proposed change.

(2) Create the possibility of a new or different kind of accident from any previously evaluated.

No new possibility for an accident is introduced by incorporating operability and surveillance requirements for the reactor coolant inventory tracking instrumentation. The equipment addressed by the proposed change is not a part of plant control instruments or safety system actuation circuitry and is used only for operator information. Requirements related to systems that have only a passive monitoring function do not create the possiblity of a new or different kind of accident.

(3) Involve a significant reduction in the margin of safety.

Addition of operability and surveillance requirements for the reactor coolant inventory tracking instrumentation constitutes an additional control not presently ircluded in the ANO-1 and 2 Technical Specifications and will require that this equipment is properly maintained. The new and more stringent requirements related to equipment which provides additional operator information may therefore enhance the margin of safety. The potential for display of misleading information from this instrumentation has been evaluated and appropriately addressed and incorporated into plant emergency operating procedures.

, The NRC has provided guidance concerning the application of these standards I

by providing examples of changes involving no significant hazards considerations. The proposed amendment most closely matches example (ii):

a change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, e.g. , a more stringent surveillance requirement. The addition of specific operability and surveillance

. requirements for the ANO-1 and 2 reactor coolant inventory tracking portions of the ICC instrumentation systems clearly constitutes additional controls not presently included in the ANO-1 and 2 Technical Specifications.

Therefore, based on the evaluation discussed above, AP&L has concluded that the proposed change does not involve a significant hazards consideration.