ML20101R568

Safety Evaluation Supporting Amend 161 to License DPR-51

ML20101R568
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/07/1992
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20101R566	List: ML20101R562 ML20101R568
References
NUDOCS 9207160085
Download: ML20101R568 (5)

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UNITED STATES E

NUCLEAR REGULATORY COMMISSION s

f W ASHINoTON. D.C. 20565 SAFETY EVALV81LQ_tLBY THE Offl(LQf_JMGLEAR REACTOR MfpLAUDff ret ATED TO AMENDMENT tlQ,161 TO FACILITY OPERATING LICEtiSE NO. DP_Bdl filIERGY OPERATIONS. INC, ARKANSAS NQ(LEAR ONE. UfLLT_lbb Q.01KET NQ __50-3))

1.0 I!iTRODUCTlQ!i By letter dated June 27, 1991, as supplemented December 20, 1991, Entergy Operations, Inc. (the licensee) submitted a request for changes to the Arkansas Natlehr One, Unit No. 1 (ANO-1) Technical Specifications (TSs). The reouested changes would revise the plant TSs based on the recommendations p,ovided by the staff in Generic letter (GL) 87-09 related to the applicability of limiting conditions for operation (LCO) and the surveillance requirements of TS 3.0 and 4.0.

The proposal revises 100 Section 3.0.4 and Surveillance Requirement Section 4, their associated Bases, and those associated TSs which no longar need to be exeapt from the provisions of TS 3.0.4 due to its rewording. Section 4 is reformatted for clarity and consistency with GL 87-09 and the licensee':, inservice Inspection and Testing Program.

SpecifItally:

Spacification 3.0.4 is revised to define when its provisions apply:

i.e., when the affected action statements permit continued operation for an unlimited period of time, instead of defining when the provisions of Specification 3.0.4 do not apply.

Specification 4.0.3 incorporates a 24-hour delay in Implementing Action requirements due to a missed surveillance when the Action requirements provide a restoration time that is less than 24-hours.

Specification 4.0.4 clarifies that "This provision shall not prevent passage through or to operational mode: as required to comply with Action requirements."

Also, a specific exemption to the provisions of TS 4.0.4 has been added to Item 31 of Table 4.1-1.

The "0CAN129105, Forwards Response to NRC 910819 Request for Addl Info Re 910627 Application for Amends to Licenses DPR-51 & NPF-6, Changing Tech Specs to Incorporate [[generic letter" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Re 3.0.4 Exceptions|December 20, 1991, letter]] provided clarifying information that did not I

change the initial proposed no significant ha::ards consideration l

determination.

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2.0fEVALUATIQN t

The changes proposed by the licensee have been reviewed considering the

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limitations set forth in GL 87-09 for TS 3.0.4, 4.0.3 and 4.0.4 as follows:

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Sp g ifigation 3.Q d

.GL. 87-09 recognizes, in part, that Specification 3.0.4 unduly restricts facility operation when conformance to the Action requirements provides an

-acceptable level of safety for continued operation in any mode. For an Lt0 that has-Action requirements permitting continued operation for an unlimited period of. time, entry into an operational mode or other specified condition of operation should be permitted in acccrdance with those Action requirements.

The: restriction on change in. operational modes or other specified condittens should apply only where the Action requirements establish a specified time

interval in which the LCO must be met or a shutdown of the facility would:be-required or where entry into that aperational mode would result in entry into-an Action statement with such time: constraints. However, nothing in the staff

'positionistated in GL 87-09 should be interpreted as endorsing or encouraging plant startup.with inoperable equipment. The GL 87-09 itself states that startup with: inoperable equipment should be the exception rather than the

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The licensee has provided ionfirmation-that the remedial measures prescribed

by the Action statement for each change involving Specification 3.0.4 is

-consistent with4he-updated Safety Analysis Report and its supporting safety analyses.- Further, the. licensee has provided' confirmation and certification 1

that appropriate-administrative controls and procedures are in place for H

-limiting-the use of. Specification 3.0.4 exceptions in conjunction with its proposed TS change submitted in response:to GL 87 09. Additionally, no

changes?are

proposed that affect plant configuration, setpoints, operating parameters,iortheoperator/ equipment. interface.

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TBased on review of theTiicensee's proposal and confirmaticns related above, we' conclude in granting.the: exceptions proposed in respor.se to GL-F7-09 that:

.1) the remedial-measures prescribed by the Action statement for each change involving the' applicability of the Specification 3.0.4 exception should=

providia sufficient level of protection to permit operational mode changes-landJsafeilong-term v,:eration consistent with the plant's Safety Analysis-h LReport; andr2) the licensee has in place adequate administrative controls and 3

' procedures which wi?l' ensure that~ it-will be the exception rather than the b

rule that startup;of the plant with'important safety features inoperable will L

occur.

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We,- tharefore,: find the following change to-Specification 3.0.4 proposed by_

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= the licensee; to be acceptable:

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" Entry / nto a' Re' actor Operating' Condition or other specified condition shall i

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not'be made when the conditions-for the' Limiting Conditions for Operation are

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not. met and the~ associated ' action-requires a shutdown if they are not met l

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a within a specified time interval. Entry into a Reactor Operating Condition or iother specified condition may be'made in.accordance with Action requirements

-when conformance to them permits continued operation of the facility for an unlimited period of time."

i 4pagific.ation__4.0.3 I

'In-GL 67-09 the staff stated that it is overly conservative to assume that systems or components are inoperable when a surveillance requirement-has not t

been pe-forced, because the vast ma,1ority of surveillances demonstrate that

' systems:or_ components in fact are operable. _Because the allowable outage time

. limits of:some Action requirements do not provide an appropriate time-limit for: performing > a missed survelilance before shutdown requirements. apply, the 9

TSs should include a time limit that would allow a-delay of the required

= actions to permit the performance of the missed surveillance.

This time limit should be based'on considerations of_ plant conditions, 1 adequate planning, availability of personnel, the time required to perform the surveillance,' as well as the safety significance of the delay in completion of the turveillance; After reviewing possible limits, the staff concluded that, based

ca.these' considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptr.ble time limit for

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- completing a missed surveillance when the allowable outage times et the Action J

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. requirements arelless than this time limit--or when shutdown Action T

-requirements 1pply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this' period against theirisks' associated with the potential for a plant upset and challenge to

= safety systems when toe alternative is"a shutdown:to comply with Action requirements-before the surveillance' can be completed.

ThisLlimit does not waive ccmpliance with Specification 4.0.3.

Under-Specification 4,0.3, the failure to perform a surveillance requirement will continue to constitute noncompliance with the operability requirements of an LCOJand to bring Jinto__ play the applicable' Action l requirements.

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Based o'nithe above~,1 the? following change to Specification _4.0.3 is acceptable:

" Failure to perform!a Surveillance Requirement within theiallowed.

. surveillance interval, defined by Specification 4.0.2 shall constitute L

noncompliance with the.0PERABILITY requirements-for.a_ Limiting Condition J

for Operation. The time' limits of:the Action requirements are applicable ac the time it is identified that a Surveillance-Requirement has not been

, 'NT performed._-The time at which the Action is taken may be delayed for up w

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to 24. hours to permit the completion of the surveillance when the-allowable outage-time limits of the: Action requirements ~are less than-

24. hours."

g Specificatior. 4;0'.4 L

TS!4.0.4; prohibits entry into an operational condition or other specified-

. condition untiltall required surveillances have been performed. This could l

cause an interpretation problem when operational condition changes are a

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required in' order to comply with Action statements. Specifically, two E.

? possible conflicts between TSs 4.0.3 and 4.0.4 could exist. The first.

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. conflict 4 arises because TS 4.0,4 prohibits entry into an ~ operational mode or A

-other specified condition when surveillance requirements have'not been-performed within the specifiel surveillance interval. The proposed modification to resolve this conflict involves the revision to-TS 4.0.3 to permit a delay of up'to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application of the Action requirements, as' explained above, and a clarification of TS 4.0.4 to-allow

-passage.through or to operational modes' as required to comply with Action requirements. The'second potential = conflict between 1Ss 4.0.3 and 4.0.4 -

arises because~an exception'to.the requirements of 4.0.4 is. allowed when surveillance-requirements can only be completed after entry into a mode or.

condition. However, after entry into this mode or condition, the requirements ofcTS;4.0.3 may-not be met.because the surveillance requirements may not have

. been ' performed within' the allowable surveillance interval.

The licensee proposes to resolve these conflicts by providing the following clarifying: statement to TS 4.0.4:

"This. provision shall not prevent passage through or to operational modes as required to comply with Action = requirements."

The NRC staff'has provided in CL 87-09 a clarification that:- (a) it is not-

the intent of 4.0.3 that the Action requirements preclude the performance of

.surveillances allowed under.any exception to TS 4.0.4; and (b).that the delay

of' up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> _ in TS 4.0.3-for the applicability of Action requirements provides an appropriate time limit for. the completion of surveillance

' requirements that become applicable as a: consequence of any-exception to

.TS 4.0.4..

Consequently 3 tthe NRC staffifinds the proposed changes to TS 4.0.4 acceptable, item 31 of Table '4.1-1 The: licensee proposes (an exception to the provisions of.TS 4.0.4 for the-18-month surveillance test of the turbine overspeed trip mechanism. According.

to the, licensee (per'telcon), following a refueling outage, the overspeed trip 7"

Ltest cannot be performed ~without: changing modes. JThe test-is! performed by.

operating the= main' turbine at k 10% -load: for: a: period greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, runloading theLturbine, and injecting a test signal to increase turbine speed y

Lto the overspeed trip setpoint. However, TS 4.0'.4 prohibits entry into a ihigher mode.:of ~ operation:until all required surveillances have been performed.

.Therefore, an exception-to TS 4.0.4~ for the overspeed trip test is s

appropriate, and the staff finds the proposed change to Item 31 to be

-acceptable.-

3.0 L STATE C_@MLTAIJM n

sin-accordance with the Commission's-regulations, the Arkansas State official

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Nas~ notified of the proposed issuance of the amendment. The State official p

-had no. comments.

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4.0 Diy.]AMMENTAl-CONSIDERATI@

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.The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements. The NRC staff has determined that the amendment involves no significant-increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that.there is no significant increase in individual or cumulative occupational radiation exposure.

The Comission has previously issued a pro-pased finding that the amendment involves no significant hazards consideration, and there has been no public coment on such finding (56 FR 41581). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental-impact statement or environmental assessment need be prepared in ccnnection with the issuance of the amendment.

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.C2LCL%LQB The Comission has concluded, based on the considerations discussed above, that:. (1) there is reasonable assurance that the health and safety of the public will not_ba endangered by operation in the proposed manner, (2) sucn i

activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical-to the comon defense and security or to the health and safety of the public.

4 Princioal Contributor:

T. Alexion Date: July 7,1992 i

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