ML19327B450

Application for Amend to License DPR-51,clarifying Tech Spec 3.2.1.2 Re Sys Piping & Valves Necessary to Establish Flow Path from Tank to Makeup Sys

ML19327B450
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
ML19327B451	List: ML19327B450 ML19327B452
References
1CAN108901, NUDOCS 8910310218
Download: ML19327B450 (6)

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, arkenees Power & Light Company  ;

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""*""" P. o Boa 651 Litte Rot A Arkernas /2203 i felbO13773b?$

T. O. Comptell UU*** [

i October 19, 1989 i

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>g. f 1CAN1P8951 .j N U. S. Nuclear Regult. tory Com:missiors  !

Document Control Desk  !

Mail Station P1 137 I Washingtor, DC 00555 l l

SUL9FtT: Arkansas Nuc* sear One - Unit 1  !

Docket Ho. 50-313 i License No. OPR-51 i Technical Specification Chant,e Request -

Clarification of Technical Specification 3.2.1.2 Gentlemen:

Arkansas Power & Light (AP&L) has identified a change to the ANO-1 Technical

- Specification (TS) 3.2.1.2 which is necessary to clarify an apparent ambiguity in the interpretation of a Limiting Condition for Operation (LLO).

TS 3.2.1.2 states in part that " System piping and valves necessary to establish a tlow path from the tank to the makeup system shall also be operable and shall have a least the same temperature as the boric acid addition tank." The basis section for this specification states that the concentration of boron in the boric acid addition tank may be higher than the concentration which would crystallize at ambient conditions. For this reason and to assure & flow of boric acid is available when needed this tank and its associated piping will be kept at least 10'F above the crystallization tempe.aature for the concentration present. AP&L, therefore, proposes to clarify the requirement with respect to temperature for the piping and valves by changing from a comparison to the tank temperature to a temperature of at least 10*F above the crystallization temperature for the concentration in the tank.

In accordance with 10CFR50.91(a)(1), and using the criteria in 10CFR50.92(c). AP&L has determined that this change involves no significant hazards consideration. Our basis for this determination and copies of the proposed change are attached for your review.

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%l, An Entetpy Company

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U .S. NRC  :

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October 19, 1989 t'-

AP&L requests that the effective date for this change be 30 days after NRC '!

issuance of the amendment to allow for distribu; den and procedural ,

revisions necessary to implement this change. ,

Very truly yours, j ffgh ' /

-T. G. Camp 11 I TGC/1w l Attachments j cc: Mr. Robert Mertin ,

U. S. Nuclear Regulatory Commission .

Region IV ,

611 Ryan Plaza Drive, Sutta 1000 t

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Arlington, TX 76011  !

NRC Senior Resident Inspector  ;

Arkansas Nuclear One - ANO-1 & 2 t Number 1, Nuclear Plant Road l Russellville, AR 72801  !

Mr. C. Craig Harbuck f 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 l Rockville, Maryland 20852 ,

i Mr. Chester Poslusny .[

NRR Project Manager, Region IV/ANO-2 {

U. S. Nuclear Regulatory Commission  ;

NRR Mail Stop 13-D-18 l One White Flint North  !

11555 Rockville Pike l Rockville Maryland 20852 [

Ms. Greta Dieus, Director  !

Division of Radiation Control  ;

and Emergency Management Arkansas Department of Health .

4815 West Harkham Street  !

Little Rock, AR 72201 i

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-I, T. Gene Campbell, being duly sworn, subscribe to and say that I am j Vice President, Nuclear for Arkansas Power & Light Company; that I have full ,

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

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[,,7 + j. . ICAN198901 and know the contents thereof; and that to the best of my [

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knowledge, informatior, and belief the staterents in it are true.

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T. G2na Campbelt l

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c SUBSCRIBED AND SWORN T0 before me, a Notary Public in and for the i County and State above named, this M ay of h ,

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PROPOSED TECHNICAL SPECIFICATION CI:ANGE' -

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i ARKANSAS POWER-4' LIGHT COMPANY' i s

4 .s ARKANSAS NUCLEAR ONE,. UNIT 1 ". i 3

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O PROPOSED CHANGE It is proposed that page 3.2 and Basis for 3.2 of the ANO-1 Technical Specification be changed as indicated on the revised copies of the pages attached to this transmittal.

DISCUSSION The proposed amendment would clarify Technical Specification 3.2.1.2 by changing the temperature maiiltained in the boric acid system piping and valves from "at least the same temperature as the boric acid addition tank" to "a temperature of at least 10'F above the crystallization temperature for l the concentratien in the tank."

p Flow f.hrough the piping durfnt routine surveillwees and nonnel makeup to l the Reactor Coolant System FK.sr9s the piping contentration is at that of  :

o tP6 Bcric Acid Tonk, j i

BACKGROUND 4 ttated in the baris for this specification, the concentration in the '

boric acid addition tank (and system piping and valves) may be higher than  :

toe concentration that would crystallize at ambient conditions. For this  !

reason and to assare a flow of boric acid ib available when needed this tank ,

and its associat?d piping will be kept at least 10"r above the  ;

crystallization temperature for the concentratioh in the tank. Changing the comparison of the piping and valves from the tank temperature to a e temperature of at least 10'F above the crystallization temperature for the concentration in the tank will assure unambiguous interpretation of this  !

requirement.

DETERMINATION OF NO SIGNIFICANT HAZARDS In accordance with 10CFR50.92, AP&L has evaluated whether the proposed change involves a significant safety hazards consideration. AP&L has concluded that the proposed change to clarify Specification 3.2.1.2 does not involve a significant hazards consideration because the operation of Arkansas Nuclear One, Unit 1 in accordance with this change would not: ,

(1) Involve a significant increase in the probability or consequences of an i accident previously evaluated. l The proposed change would not alter the probability of any previously analyzed accident occurring. The proposed change simply clarifies the temperature requirement of the boric acid system piping and valves to l

I 9liminate ambiguity. This will not impact the accident-mitigating l

events described in Chapter 14 of the ANO-1 SAR. Further the proposed

, change will not adversely affect the consequences of accidents which have been previously evaluated. The proposed change simply clarifies

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B' the temperature requirement of the boric system piping and valves to reduce ambiguity and therefore increases the ability to mitigate the consequences of postulated accidents.

(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 clarifying the.

requirement for boric acid system piping and valves. The proposed amendment will not change the overall desian and system function of the boric acid system. The temperature control system is based on a predetermined setpoint rather than an boric acid addition tank

': r temperaturo. The proposed change simply eliminates the potential for misinterpretation of the temperature requirement for the boric acid n9 tem.

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.(3)~' Involve e.siiinifia nt re. duction in the margin of safety.

The proposed change provides, for a clarif t:ation of the temperature

c. requirement for tite toric acid system piping and valves which will '

i reduce the ambiguity of the specification. This change does not y involve a significent reduction in the margin of safety, and in fact will increase the margin of safety by reducing the ambigotty of the

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temperature requirement and therefore its capabilitics to ultigate

- accidents.

The NRC has provided guidance concerning the application of these standards by providing examples of changes involving no signifiednt hazards considerations. The proposed amendment most closely matches example (1):

"A purely administrative change to technical specifications: for example, a

. change to achieve consistency throughout the technical s)ecifications, correction of an error, or a change in nomenclature." T1e proposed change provides consistency in verbage of the temperature specifications to reduce ambiguity.

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

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