ML20012E161

Application for Amend to License NPF-6,modifying Tech Spec 4.10.2.2 & 3.10.2 Re Special Test Exception

ML20012E161
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/02/1990
From:	Carns N ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20012E162	List: ML20012E161 ML20012E164
References
2CAN039007, 2CAN39007, NUDOCS 9003300148
Download: ML20012E161 (6)

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i March 2, 1990 4 2CAN839987 j U. S. Nuclear Regulatory Commission  ;

Document Control Desk Mail Station P1-137 Washington, DC. 20555 l

Subject:

Arkansas Nuclear One - Unit 2 Docket No. 50*368 i License No. NPF-6 Technical Specification Change Request -

Special Test Exception 3/4.10.2 Gentlemen:

An Arkansas Nuclear One (ANO) Quality Assurance audit revealed a discrepancy in the ANO-2 Technical Specifications (TS) regarding the particular method of monitoring linear heat rate (LHR) at certain power levels during the

-power ascension phase of startup physics testing. Specifically, TS 4.10.2.2 requires that LHR be determined to be within the limits of TS 3.2.1 by ,

monitoring it continuously with the Incore Detector Monitoring System pursuant to the requirements of TS 4.2.1.3 and 3.3.3.2 during physics testing above 5% rated thermal power (RTP) when Special Test Exception l 3.10.2 is in use. . The language requiring use of the incore detectors implies use of the Core Operating Limit Supervisory System (COLSS) to L monitor LHR. However, TS 3.2.1 is not applicable below 20% RTP and COLSS is L

not considered operable.below 20% RTP. ANO has evaluated this discrepancy l- and determined that use of the Core Protection Calculators (CPC) for monitoring LHR is appropriate to meet the intended requirement of TS 4.10.2.2. The CPC use a minimum core average power of 20% RTP to '

calculate heat flux, which results in conservative values of LHR being calculated below 20% RTP. We therefore proposes to modify TS 4.10.2.2 by l deleting the language specifically requiring use of the incore detectors,  ;

and also to modify relatqd TS 3.10.2 to clarify the specific requirements I:

l for maintaining LHR. A copy of the proposed change is attached for your L review and approval.

l In accordance with 10CFR50.91(a)(1), and using the criteria in 10CFR50.92(c), 1 it has been 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 emergency.

I 9003300148 900302 D 1

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'U. S. NRC j Page 2

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March 2, 1990 i We request that the effective date for this change be 30 days after NRC issuance of the amendment to allow for distribution and procedural ,

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revisions necessary to implement this change.  !

V Very truly yours, t

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N. S. Carns

Vice President, Nuclear i

NSC/rbt Attachment

. cc: Mr. Robert Martin U.~ S. Nuclear Regulatory Commission i 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. Thomas W. Alexion 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 Posiusny i 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 I Little Rock, AR 72201 U

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' STATE OF ARKANSAS )

) SS COUNTY OF POPE )

I, N. S. Carns, 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 2CAN039007 and know the contents thereof; and that to the best of my knowledge, information and belief, the statements in it are true.

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N. S. Carns SUBSCRIBED AND SWORN T0 before me, a Notary Public in and for the County and State above named, this ' 2. day of M%xfl_ ,

1990.

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Notary Public l

My Commission Expires:

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E PROPOSED TECHNICAL SPECIFICATION CHANGES l n e p,  !

u' LICENSE AMENDMENT REQUEST.- i IN THE MATTER OF AMENDING i

I- LICENSE NO. NPF-6

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ARKANSAS POWER &' LIGHT COMPANY I ARKANSAS NUCLEAR ONE,' UNIT 2 l

DOCKET NO. 50-368  !

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' DESCRIPTION OF PROPOSED CHANGE Special Test Exception 3.10.2 permits individual Core Element Assemblies (CEA) and/or CEA groups to be positioned outside of their normal group heights and insertion limits during the performance of certain required physics tests, provided certain monitoring requirements are met. This proposed change will modify Special Test Exception 3.10.2 to clarify the specific requirements for mak.te*ning linear heat rate (LHR), and modify the related Surveillance Requirement (SR) 4.10.2.2 to delete the language specifically requiring use of the Incore Detector Monitoring System for determining LHR.

BACKGROUND An Arkansas Nuclear One (ANO) Quality Assurance audit revealed a discrepancy in the ANO-2 Technical Specifications (TS) regarding the particular method of monitoring linear heat rate (LHR) at certain power levels during the power ascension phase of startup physics testing. Specifically, TS 4.10.2.2 requires that LHR be determined to be within the limits of TS 3.2.1 by monitoring it continuously with the Incore Detector Monitoring System pursuant to the requirements of TS 4.2.1.3 and 3.3.3.2 during physics testing above 5% rated thermal power (RTP) when Special Test Exception 3.10.2 is in use. The language requiring use of the incore detectors implies use of the Core Operating Limit Supervisory System (COLSS) to monitor LHR. The NRC Safety Evaluation associated with ANO-2 TS Amendment 37 stated that the inclusion of TS 3.1.3.7 in TS 3.10.2 for special test exceptions was acceptable since adequate surveillance requirements and '

appropriate actions are specified if the LHR exceeds its limits as specified in TS Figure 3.2-1. Figure 3.2-1 provides limits for LHR with COLSS out of service. Also, TS 3.2.1 is not applicable below 20% RTP and COLSS is not considered operable below 20% RTP. Therefore, the specific requirement for use of incore detectors (i.e., COLSS) is not appropriate in TS 4.10.2.2.

ANO believes that TS 4.10.2.2 should have been revised when TS Amendment 79 was issued to allow use of the Core Protection Calculators (CPC) to monitor LHR with COLSS out of service.

DISCUSSION This discrepancy has been evaluated and it has been determined that use of the CPC for monitoring LHR is appropriate to meet the intended requirement of TS 4.10.2.2. The CPC use a minimum core average power of 20% RTP to calculate heat flux, which results in conservative values of LHR being calculated below 20% RTP. The indication system which should be utilized for satisfying SR 4.10.2.2 (when COLSS is out of service) is any operable CPC channel, as allowed by TS 3.2.1.b. This method is in agreement with the NRC Safety Evaluation associated with issuance of ANO-2 TS Amendment 79.

We therefore proposes to modify TS 4.10.2.2 by deleting the language specifically requiring use of the incore detectors, and to modify TS 3.10.2 to clarify the requirements for maintaining LHR when the Special Test Exception is invoked during physics testing. The proposed language for TS 3.10.2 is similar to that of existing TS 3.2.1 (Linear Heat Rate).

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'OESCRIPTION OF PROPOSED NO SIGNIFICANT HAZARDS DETERMINATION In accordance with 10CFR50.92, the proposed change has been evaluated to determine if it involves a significant safety hazards consideration. It has !

been concluded that the proposed change to TS Special Test Exception 3.10.2 and the associated Surveillance Requirement 4.10.2.2 does not involve a significant hazards consideration because the operation of Arkansas Nuclear ,

One, Unit 2 in accordance with this change would not:

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

The monitoring requirements addressed by the proposed change are consistent ,

with those of the plant system currently addressed by the technical  :

specifications. The proposed change maintains the conservative restrictions '

on reactcr core linear heat rate. 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 making the specific method for monitoring reactor core linear heat rate required under the associated special test exception consistent with the method already required elsewhere in the technical specifications. The proposed change involves a passive monitoring function which does not create the possibility of a new or different kind of accident.

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

The proposed change will simply bring consistency to the method for determination of reactor core linear heat rate. The adequacy and conservatism of this determination will be maintained, and in some cases increased. The inherent margins of safety in the CPC calculation of linear heat rate have been extensively evaluated previously. The proposed change will maintain these margins in the specific use addressed by the associated requirement.

The NRC has provided guidance concerning the application of these standards by providing examples of changes involving no significant 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 specifications, correction of an error, or a change in nomenclature. A discussed above, monitoring of LHR with the CPC when COLSS is out of service has been previously evaluated during the NRC issuance of TS Amendment 79. The proposed change simply reflects this approved method of monitoring LHR in another part of the TS which was not incorporated during the change associated with Amendment 79.

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