0CAN109603, Application for Amend to Licenses DPR-51 & NPF-6 Re Relocation of RETS Per GL 89-01
| ML20128G720 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/02/1996 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128G723 | List: |
| References | |
| 0CAN109603, CAN109603, GL-89-01, GL-89-1, NUDOCS 9610090108 | |
| Download: ML20128G720 (12) | |
Text
Ent:rgy Oper: tion:,Inc.
d 1448 SH 333 Hun *@ AH 77601 Tet M1658 4388 C. Randy Hutchinson October 2,1996
$$c OCAN109603 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137 Washington, DC 20555
Subject:
Arkansas Nuclear One - Units I and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Relocation of the Radiological Emuent Technical Specifications for Units I and 2 f
Gentlemen:
Attached for your review and approval are the proposed changes to Arkansas Nuclear One Unit I and Unit 2 Technical Specifications to allow the implementation of Generic Letter (GL) 89-01. This GL allows relocation of the Radiological Emuent Technical Specifications (RETS) to the Offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP). The staff has determined that programmatic controls can be implemented in the administrative controls section of the technical specifications to satisfy the existing controls for the RETS. At the same time, the procedural details of the current technical specifications on radioactive emuents and radiological environmental monitoring can be relocated to the ODCM. Likewise, the procedural details of the current technical specifications on solid radioactive wastes can be relocated to the PCP. These changes serve to simplify the technical specifications to fulfill the goal of the Commission Policy Statement for Technical Specification Improvements.
At the same time, they continue to meet the regulatory requirements for radioactive emuents and radiological environmental monitoring.
The proposed amendment was prepared in accordance with the guidance provided in GL 89-01 as updated in the improved standard technical specifications 'NUREG 1430 and 1432.
Also attached 1 your review is a complete draft copy of the ODCM that incorporates the procedural details of the RETS as required by GL 89-01 that you may use as a reference.
I The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards considerations.
Entergy Operations requests that the effective date for this change be within 30 days of NRC issuance of the amendment to allow for distribution and procedural revisions necessary to implement the change.
t t
fbb 9610090108 961002 PDR ADOCK 05000313 P
?
U. S. NRC October 2,1996 0CAN109603 Page 2 Very truly you s, I
r CRH/rde Attachments To the best of my knowledge and belief, the statements contained in this submittal are true.
SUBSCRIBED AND SWORN TO before me, a Notary Public in and for b/wm County and the State of Arkansas, this A day of ()rfdn
,19960 N. 0anD ham Notary Public cmcasca j
My Cominission Expires
// M djpu L '.
N sAs einsoucouun 6
MyCommisson Expres 11 6 2000 f
i l
D U. S. NRC j
October 2,1996 OCAN109603 Page 3 cc:
Mr. Leonard J. Callan i
Regional Administrator j
U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064
]
NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard Bevill Acting Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205 l
d ATTACHMENTI IQ OCAN109603 PROPOSED TECHNICAL SPECIFICATION AND RESPECTIVE SAFETY ANALYSES IN THE MATTER OF AMENDING LICENSE Nos. DPR-51 and NPF-6 ENTERGY OPERATIONS. INC.
ARKANSAS NUCLEAR ONE. UNITS ONE & TWO DOCKET Nos. 50-313 and 50-368 1
1 i
Attachment to 0CAN109603 l
Page1of8 l
DESCRIPTION OF THE UNIT 1 PROPOSED CHANGES The indexes and list of figures pages were modified to reflect the proposed page numbers, e
titles and sections. The index title for TS 3.5.5 and 6.13 were removed because these specifications were removed by previous amendments. The list of figures was also updated to reflect the current figures in the Technical Specifications (TS).
The Rfmition of the Offsite Dose Calculation Manual (ODCM) in TS 1.10.3 was e
relocated from the definitions section to TS 6.14.
- TS definitions 1.10.2,1.10.5, and 1.10.6 were relocated from the definitions section of the TS to the ODCM. This resulted in some of the other defmitions being renumbered and consolidated.
The following specifications are being relocated from the TS to the ODCM, The specific procedural details contained in these TS, including the Limiting Conditions for Operation (LCO), the Applicability, Remedial Actions, Surveillance Requirements, Tables, and Bases
)
are being relocated to the ODCM The following TS are affected: 3.5.6, 3.5.7, 3.25.1.1, 3
3.25.1.2, 3.25.1.3, 3.25.2.1, 3.25.2.2, 3.25.2.3, 3.25.2.4, 3.25.3, 4.29.1.1, 4.29.1.3, 4.29.2.1, 4.29.2.3, 4.29.3, 4.30.1, 4.30.2, and 4.3 0.3.
Pages 53d and 53e are proposed to be removed from the TS due to the relocation of the e
associated specifications by a previously approved amendment.
TS 3.25.4 and 4.29.4 are being relocated from the TS to the process control program (PCP).
The following Radiological Efiluent Technical Specifications (RETS) were renumbered and maintained in the TS with minor administrative modifications:
3.25.1.4 was renumbered to 3.25.1, 3.25.2.5 was renumbered to 3.25.2, 4.29.1.2 was renumbered to 4.29.1, and 4.29.2.2 was renumbered to 4.29.2.
Figure 5.1-1 (Page Illa) was removed from the TS due to the specifications that referred to this figure have been relocated to the ODCM. This figure is already located in the current ODCM as figure 4-2.
The title of TS 6.8 was modified to include programs as well as procedures to be included in this section.
Proposed TS 6.8.4.a adds the requirements for the Radioactive Efiluent Controls l
e Program.
Proposed TS 6.9.2.1 was added to require that records of reviews performed for changes to the ODCM and PCP be retained for the duration of the license.
3 Attichment to OCAN109603 Page 2 of 8 TS 6.12.2.5 and 6.12.2.6 were revised to be consistent with the improved standard TS, e
NUREG-1430 Revision 1, " Standard Technical Specifications Babcock and Wilcox Plants."
The special reporting requirements of TS 6.12.5.c, 6.12.5.f, and 6.12.5.g were relocated to the ODCM along with the associated specifications.
TS 6.14 was revised to be consistent with the improved standard TS.
DESCRIPTION OF THE UNIT 2 PROPOSED CHANGES The index pages were modified to reflect the proposed page numbers, titles and sections for the relocation of the RETS.
The index titles for the fire detection instmmentation and TS 6.12 were removed because e
these specifications were removed by previous amendments. The turbine overspeed protection LCO was moved from index page VI to V for con:istency with the rest of the instrumentation LCOs.
TS definitions 1.28,1.31, and 1.32 were relocated from the definitions section of the TS to the ODCM. The definition of the ODCM in TS 1.29 was relocated to specification j
6.14. This resulted in some of the other definitions being renumbered and consolidated.
The turbine overspeed protection TS was moved from page 3/4 3-58 to 3/4 3-43.
e i
The following specifications are being relocated from the TS to the ODCM. The specific l
procedural details contained in these TS, including the LCO, the Applicability, Actions, Surveillance Requirements, Tables, and Bases are being relocated to the ODCM. The following TS are affected: 3/4.3.3.9, 3/4.3.3.10, 3/4.11.1.1, 3/4.11.1.2, 3/4.11.1.3, j
3/4.11.2.1, 3/4. I 1.2.2, 3/4.11.2.3, 3/4.11.2.4, 3/4. I 1.2.5, 3/4. I 1.3, 3/4.12.1, 3/4.12.2, and i
3/4.12.3.
TS 3/4.11.4 are being relocated from the TS to the PCP.
l The following RETS specifications were renumbered and maintained in the TS with minor administrative modifications: 3.11.1.4 was renumbered to 3.11.1, 3.11.2.6 was renumbered to 3.11.2,3.11.2.7 was renumbered to 3.11.3, Table 3.11-3 was moved from page 3/4 ll-14b to 3/411-4, and Figure 3.11-1 was moved from page 3/411-14c to page i
3/411-5 with the hydrogen and oxygen coordinates points added to the figure. The note in specification 3.11.1 was modified to be consistent with the similar note in the Unit 1 specification 3.25.1. The words "and analyzed" were not retained in Action 1 of Table 4
3.11-3 to eliminate confusion on the requirements for sample analysis.
i
,i a
Attachment to OCAN109603 Page 3 of 8 The bases title for 3/4.3.3.8 was removed from the TS because the specification was e
removed by a previous amendment. The bases for specification 3/4.3.4 was moved from page B 3/4 3-5 to B 3/4 3-3.
The bases for the proposed TS 3/4.11.1,3/4.11.2, and 3/4.11.3 were consolidated to page B 3/4 11-1.
Figure 5.1-3 (Page 5-3a) was removed from the TS due to the specifications that referred to this figure have been relocated to the ODCM. This figure is already located in the current ODCM as figure 4-2.
The title of TS 6.8 was modified to include programs as well as procedures to be included in this section. The words " post accident" were separated by a space on the same page.
Proposed TS 6.8.4.a adds the requirements for the Radioective Effluent Controls Program consistent with the improved standard TS, NUREG-1432 Revision 1, " Standard Technical Specifications Combustion Engineering Plants."
Relocated TS 6.9.2.h,6.9.2.1, and 6.9.2.m special reporting requirements to the ODCM I
e l.
with the associated specifications. The reference to TS 3.3 was corrected to 3.3.3.1 for i
clarity in section 6.9.2.o.
TS 6.9.3 and 6.9.4 were revised to be consistent with the improved standard TS.
e l
Proposed TS 6.10.2.m was added to require that records of reviews performed for changes to the ODCM and PCP be retained for the duration of the license.
Proposed revision to TS 6.14 revises this section to be consistent with improved standard e
l TS.
l BACKGROUND Generic Letter (GL) 89-01 allows relocation of the Radiological Efiluent Technical Specifications (RETS) to the ODCM and PCP. The staff has determined that programmatic controls can be implemented in the administrative controls section of the technical specifications to satisfy the existing controls for the RETS. At the same time, the procedural details of the cu rent TS on radioactive effluents and radiological environmental monitoring could be relocated to the ODCM. Likewise, the procedural details of the current technical specifications on solid radioactive wastes can be relocated to the PCP. These changes serve to simplify the TS and fulfill the goal of the Commission Policy Statement for Technical Specification Improvements.
At the same time, they continue to meet the regulatory requirements for radioactive effluents and radiological environmental monitoring.
The proposed amendment was prepared in accordance with the guidance provided in Genenc q
Letter 89-01.
1 1
\\
k
AttachmInt to 0CAN109603 Page 4 of 8 j
l The specific guidelines for Technical Specifications required to meet 10 CFR 50.36a and 10 CFR 50, Appendix I, are provided by GL 89-01. These guidelines are followed in this 4
amendment request and updated to the latest revision of the associated improved standard TS, i
except for some minor administrative changes.
ANO has previously committed to implementation of the improved standard TS (0CAN069502) with the Unit 1 project currently well under way.
DISCUSSION OF THE UNIT I PROPOSED CHANGES i
The indexes and list of figures pages were modified to reflect the proposed page numbers, titles and sections. The index titles for TS 3.5.5 and 6.13 were removed because these i
specifications were removed by previous amendments. The list of figures was also updated to reflect the current figures in the TS These changes are considered administrative in nature.
l TS definitions 1.10.2,1.10.5, and 1.10.6 were removed from the definitions section of the TS and relocated to the ODCM. The definition of the ODCM in TS 1.10.3 was relocated to TS i
6.14. This resulted in some of the other definitions being renumbered and consolidated.
These changes are consistent with the improved standard TS.
The following specifications are being relocated from the TS to the ODCM. The specific procedural details contained in these TS, including the Limiting Conditions for Operation, their Applicability, Remedial Actions, Surveillance Requirements, Tables, and Bases are being relocated to the ODCM. The following TS are affected: 3 5.6, 3.5.7, 3.25.1.1, 3.25.1.2, 3.25.1.3, 3.25.2.1, 3.25.2.2, 3.25.2.3, 3.25.2.4, 3.25.3, 4.29.1.1, 4.29.1.3, 4.29.2.1, 4.29.2.3, 4.29.3,4.30.1,4.30.2, and 4.30.3. These changes are consistent with GL 89-01 and with the improved standard TS.
The following RETS specifications were renumbered and maintained in the TS as required by GL 89-01: 3.25.1.4 was renumbered to 3.25.1, 3.25.2.5 was renumbered to 3.25.2, 4.29.1.2 was renumbered to 4.29.1, and 4.29.2.2 was renumbered to 4.29.2. The improved standard TS includes these specifications into a program that will occur as each unit converts to the i
improved standard TS.
Specification 3.25.4 and 4.29.4 are being relocated from the TS to the PCP in accordance with GL 89-01 and the improved standard TS.
Figure 5.1-1 (Page 111a) was removed from the TS due to the specifications that referred to this figure have been relocated to the ODCM This figure was added to section 5 of the TS by the same amendment that added the RETS. This figure is already located in the current ODCM as Figure 4-2. This change is consistent with the improved standard TS.
The title of TS 6.8 was modified to include programs as well as procedures to be included in this section. This change is consistent with GL 89-01.
2 7
i Attachment to OCAN109603 j
Page 5 of 8 f
Proposed TS 6.8.4.a adds the requirements for the Radioactive Effluent Controls Program.
This change is consistent with GL 89-01 and the improved standard TS.
1 Proposed TS 6.9.2.1 was added to require that records of reviews performed for changes to i
the ODCM and PCP be retained for the duration of the license. This change is consistent with
]
TS 6.12.2.5 and 6.12.2.6 were revised to be consistent with the improved standard TS.
l l
The special reporting requirements of TS 6.12.5.c, 6.12.5.f and 6.12.5.g were relocated to the ODCM along with the associated specifications. This change is consistent with GL 89-01.
l TS 6.14 was revised to be consistent with the improved standard TS. The indication of the implementation date on changes to the ODCM may be satisfied by the date being indicated on a cover sheet or on each revised page.
l DISCUSSION OF THE UNIT 2 PROPOSED CHANGES i
l The index pages were modified to reflect the proposed page numbers, titles and sections. The l
index titles for the fire detection instrumentation and TS 6.12 were removed because these j
specifications were removed by previous amendments. The turbine overspeed protection i
LCO was moved from index page VI to V for consistency with the rest of the instrumentation LCOs. These changes are considered administrative in nature.
i l
TS definitions 1.28,1.31, and 1.32 are being relocated from the definitions section of the TS to the ODCM. The definition of the ODCM in TS 1.29 was relocated to Specification 6.14.
This resulted in some of the other definitions being renumbered and consolidated. These changes are consistent with the improved standard TS.
j The turbine overspeed protection specification (3/4.3.4) was moved from page 3/4 3-58 to 3/4 l
3-43 to allow removal of the RETS pages. This change is considered administrative in nature.
The following specifications are being relocated from the TS to the ODCM. The specific j
procedural details contained in these TS, including the Limiting Conditions for Operation, their Applicability, Remedial Actions, Surveillance Requirements, Tables, and Bases are being relocated to the ODCM. The following TS are affected: 3/4.3.3.9, 3/4.3.3.10, 3/4.11.1.1, I
3/4.I1.1.2, 3/4.I'l.1.3, 3/4.I1.2.1, 3/4.11.2.2, 3/4.11.2.3, 3/4.I1.2.4, 3/4.I1.2.5, 3/4.11.3, 3/4.12.1,3/4.12.2, and 3/4.12.3. These changes are consistent with GL 89-01 and with the improved standard TS.
j Specification 3/4.11.4 will be relocated from the TS to the PCP. This change is consistent
)
with GL 89-01 and the improved standard TS.
1 i
1
Attachment to 0CAN109603 Page 6 of 8 The following RETS specifications were renumbered and maintained in the TS as required by GL 89-01: 3.11.1.4 was renumbered to 3.11.1, 3.11.2.6 was renumbered to 3.11.2, 3.11.2.7 was renumbered to 3.11.3, Table 3.11-3 was moved from page 3/411-14b to 3/411-4, and Figure 3.11-1 was moved from page 3/411-14c to 3/411-5. The improved standard TS includes these specifications into a program that will occur as each unit converts to the improved standard TS. The note in specification 3.11.1 was modified to be consistent with the similar note in the unit I specification 3.25.1. The words "and analyzed" were not retained in Action 1 of Table 3.11-3 due to the confusion it created on the requirements for sample analysis. The sample analysis requi cments are clearly stated in the last sentence of Action 1 and the bases for this specification. The points (4,4) were added to figure 3.11-1 for clarity. These changes are considered administrative in nature.
The bases title for 3/4.3.3.8 was removed from the TS because the specification was removed by a previous amendment. The bases for 3/4.3.4 was moved from page B 3/4 3-5 to page B 3/4 3-3. These changes are considered administrative in nature.
The bases for the proposed specifications 3/4.11.1,3/4.11.2, and 3/4.11.3 were relocated to page B 3/411-1. These changes are considered administrative in nature.
Figure 5.1-3 (Page 5-3a) was removed from the TS due to the specifications that referred to this figure have been relocated to the ODCM. This figure was added to section 5 of the TS by the same amendment that added the RETS. This figure is already located in the current ODCM as Figure 4-2. This change is consistent with the improved standard TS.
The title of TS 6.8 was modified to include programs as well as procedures to be included in this section. This change is consistent with GL 89-01 The words " post accident" were separated by a space on the same page. This change is considered administrative in nature.
Proposed specification 6.8.4.a adds the requirements for the Radioactive Efiluent Controls Program consistent with the improved standard TS.
The special reporting requirements of TS 6.9.2.h, 6.9.2.1, and 6.9.2.m were relocated to the ODCM with the associated specifications. This change is consistent with GL 89-01. In section 6.9.2.o on the same page, the reference to TS 3.3 was corrected to 3.3.3.1 for clarity.
This change is considered administrative in nature.
Specifications 6.9.3 and 6.9.4 were revised to be consistent with Generic Letter (GL) 88-01 while ensuring these specifications are also consistent with the latest revision of the improved standard TS.
Proposed TS 6.10.2.m was added to require that records of reviews performed for changes to the ODCM and PCP be retained for the duration of the license. This change is consistent with GL 89-01.
Attachment to OCAN109603 Page 7 of 8 The proposed revision to TS 6.14 modifies this section to be consistent with improved standard TS. The indication of the implementation date on changes to the ODCM may be satisfied by the date being indicated on a cover sheet or on each revised page.
DETERMINATION OF NO SIGNIFICANT IIAZARDS CONSIDERATION An evaluation of the proposed change has been performed in accordance with 10 CFR 50.91(a)(1) regarding no significant hazards considerations using the standards in 10 CFR 50.92(c). A discussion of these standards as they relate to this amendment request follows:
Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
The proposed changes are considered administrative in nature. These changes alter only the location of programmatic controls and procedural details relative to radioactive effluents, radiological environmental monitoring, solid radioactive wastes, and associated reporting requirements.
Compliance with applicable regulatory requirements will continue to be maintained. In addition, the proposed changes do not alter the conditions or assumptions in any of the Safety Analysis Report (SAR) accident analyses. Since the SAR accident analyses remain bounding, the radiological consequences previously evaluated are not adversely affected by the proposed changes.
Therefore, this change does not involve a significant increase in the probability or consequences of any accident previously evaluated.
Criterion 2-Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.
The proposed changes do not involve any changes to the configuration or method of operation of any plant equipment. The proposed changes are considered administrative in nature. Accordingly, no new failure modes have been defined for any plant system or component important to safety nor has any new limiting single failure been identified as a result of the proposed changes. Also, there will be no change in types or increase in the amounts of any radioactive effluents released offsite.
Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated.
Attachment to OCAN109603 Page 8 of 8
?
Criterion 3 - Does Not involve a Significant Reduction in the Margin of Safety.
The proposed changes do not involve any actual change in the methodology used in the control of radioactive effluents, solid radioactive wastes, or radiological environmental monitoring. These changes are considered administrative in nature and provide for the relocation of procedural details outside the Technical Specifications. This change adds appropriate administrative controls in tte Technical Specifications to provide continued assurance of compliance with applicable reg tlatory requirements.
j Therefore, this change does nqt involve a sigt ificant reduction in the margin of safety.
i Therefore, based upon the reasoning prestated above and the previous discussion of the amendment request, Entergy Operations has determined that the requested change does nql i
involve a significant hazards consideration.
1 j
i 4
4 4
d il i
)
4