ML19327B443

Application for Amend to License DPR-51,replacing 1 Gpm Limit on Total primary-to-secondary Leakage from Any One Steam Generator,Per Generic Ltr 85-02

ML19327B443
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/19/1989
From:	Tison Campbell ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19327B444	List: ML19327B443 ML19327B445
References
1CAN108902, GL-85-02, GL-85-2, NUDOCS 8910310208
Download: ML19327B443 (6)

Text

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<: i L A#hensee ,,

f , <t Powet & Light Company 426 West CMwtot i

f - "' P o. Boa 141 l Little Rock. Arkanset 72203 i

-i Ted 601377 3!,25 i i>

,J f T G. Campbell l

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i October 19, 1989 1

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't ICtR198982 f U. S. Nuclear Regulatory Commission fi Document Control Desk Mail Station P1-137  !

Washington, DC 20555  :

Subject:

Arkansas Nuclear One - Unit 1 i Docket No. 50-313 ,

License No. OPR-51  !

Technical Specification Change Request - l Primary-to-Secondary Leakage Rate Limit ,

Gentlemen: (

i Amendment No.115 to the ANO-1 Technical Specifications (TS), dealing with  !

reactor coolar.t system leakage, added a 1.0 gpm total leak rate limit  !

through the tubes of both steam generators based on the NRC staff recommended  !

actions in Generic Letter 85-02. In order to meet recommendations of ,

G.L. 85-02, Arkansas Power & Light Company proposes to modify the ANO-1 TS  ;

to replace the current 1.0 gpm limit on total primary-to-secondary leakage i with an explicit 500 gpd (0.347 gpm) limit on primary-to-;tcondary leakage i from any one steam generator, j AP&L requests that the effective date for this change be 30 days after NRC l issuance of the amendment to allow for distribution and procedural  ;

revisions necessary to implement this change. .:

Very truly yours, ,

A/

1 T.'G. Cam ell 1'

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l U. S. NRC Paga 2 October 19, 1989 cc: Mr. Robert Martin U. S. Nuclear Regulatory Commission f- Region IV

! 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011

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l NRC Senior' Resident Inspector Arkansas Nuclear One - ANO-1 & 2

l. 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 13-0-18 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Chester Posiusny NRR Project Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-0-18 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Ms. Greta Dicus, Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72201

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I STATE OF ARKANSAS )

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) SS t COUNTY OF PULASKI )

k I, T. G. Campbell, being duly sworn, subscribe to and say that I am Vice President, Nuclear for Arkansas Power & Light Company; that I have full authority to execute this oath; that I have read the document numbered l

ICAN188982 and know the contents thereof; and that to the best of my knowledge, information and belief the statements in it are true, r

1. W f

T. G. Campbell t

SUBSCRIBED AND SWORN TO before me, a Notary Public in and for the County and State above named, this M ay of b d 6 L,) ,

1989.

v Notary Public My Commission Expires:

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1: ATTACHMENT f

PROPOSED TECHNICAL SPECIFICATION CHANGE f

r LICENSE AMENDMENT REQUEST l r

IN THE MATTER OF AMENDING i LICENSE NO. DPR-51 ,

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ARKANSAS POWER & LIGHT COMPANY ARKANSAS NUCLEAR ONE, UNIT 1 ] k DOCKET NO. 50-313 [

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i DESCRIPTION OF PROPOSED CHANGE l

I" The proposed change revices ANO-1 Technical Specification 3.1.6.3.b, which addresses limiting conditions for operation (LCO) with reactor coolant system leakage. Specifically, it adds sn explicit 500 gallons per day (gpd) limit on primary-to-secondary leakage (0.347 gpm) from any one steam generator to replace the current 1.0 gpm limit on total primary-to-secondary

! leakage. Specification 4.18.4.c.1 is also revised to include additional unscheduled inservice inspections whenever leakage occurs in excess of the limit in Specification 3.1.6.3.b in lieu of radiciodine activity limits in the secondary coolant per Specification 3.10.

DISCUSSION i

NRC staff-recommended actions contained in the resolution of the unresolved safety issues regarding steam generator tube integrity were issued as Generic Letter 85-02. These recommendations included a recommendation that '

PWRs with less restrictiva limits than the Standard Technical Specification (STS) limits on allowable primary-to-secondary leakage adopt the STS limits; namely, a 1.0 gpm limit on total primary-to-secondary leakage and a 500 gpd (0.347 gpm) limit for leakage from any one steam generator. The 1.0 gpm .

limit was subsequently incorporated into the ANO-1 Technical Specifications  ;

by Amendment No. 115. Since the 500 gpd limit bounds the requirements for '

the 1.0 gpm leak rate, utilizing only a 500 gpd limit per steam generator does not affect safe operation of the plant. A 500 gpd limit corresponds to i the expected leakage for the maximum-sized crack length which would not be expected to fail under worst case pressure differential loadings associated with a design basis MSLB or feed line break. A 500 gpd limit per steam generator will provide en even more effective limit than the 1.0 gpm limit '

with regard to minimizing periods during which tubes may be vulnerable to rupture, given a postulated accident. Currently, Specification 4.18.4.c.1 requires an unscheduled steam generator inservice inspection (ISI) when  ;

exceeding a secondary coolant activity of 0.17 pCi/gm (Specification 3.10)  !

which was based on a postulated accidert assuming 1.0 gpm tube leakage.  ;

Based upon a maximum leak rate of 1.0 gpm, the dosage contribution from tube  ;

leakage will be limited to a small fraction of 10CFR Part 100 limits in the event of a steam generator tube rupture or main :. team line break event. The i proposed change to Specification 4.18.4.c.1 requires an unscheduled ISI when l exceeding the lakage limits of Specification 3.1.6.3.b rather than the currently used activity limit of Specification 3.10. Replacing an activity limit with a leakage limit in Specification 4.18.4.c.1 still bounds previous  ;

requirements of 10CFR Part 300 and is more conservative. For leakage in the L steam generator lane or wedge regions, performance of a 100% ISI of the  ;

affected region is also proposed in Specification 4.18.4.c.1 in lieu of a  :

random inspection specified in TS Table 4.18.2.

UETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION AP&L has performed an analysis of the proposed change in accordance with 10CFR50.91(a)(1) regarding no significant hazards consideration using the standards in 10CFR50.92(c), as follows:

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I i L (1) The proposed change does not involve a significant increase in the ,

probability or consequences of an accident previously evaluated because it simply adds an explicit requirement for a limit not currently in .,

the ANO-1 Technical Specifications. The leakage limit remains within  !

. the assumptions used in the ANO-1 SAR accident analysis which .

I' demonstrates that the consequences of design basis accidents do not .

exceed 10CFR100 limits.  ;

(2) The proposed change does not create the possibility of a new or i different kind of accident from any previously analyzed because it does not create any new accident scenario, and simply provides additional i' assurance that operation of the plant is bounded-by the assumptions used in the current accident analysis. j (3) The proposed change does not involve a significant reduction in a

• margin of safety since the proposed change adds an explicit limitation and additional inspection requirements that do not presently exist in  ;

the Technical Specifications.  ;

The Commission has provided guidance concerning the application of these standards by providing examples of amendments that are considered not likely to involve significant hazards considerations. The proposed amendment is most closely encompassed by Example (ii): A change that constitutes an additional limitation, restriction, or control not presently included in the TS. .

Therefore, based on the reasoning presented above and the previous discussion of amendment request, AP&L has determined that the requested change does not involve a significant hazards consideration.

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