ML20128H506
| ML20128H506 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/03/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20128H484 | List: |
| References | |
| NUDOCS 9610090368 | |
| Download: ML20128H506 (6) | |
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4 UNITED STATES j
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 30866-0001
.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDHENT NOS.185 AND 176 TO FACILITY OPERATING LICENSE NOS. DPR-51 AND NPF-6 ENTERGY OPERATIONS. INC.
ARKANSAS NUCLEAR ONE. UNIT NOS. 1 AND 2 DOCKET NOS. 50-313 AND 50-368
1.0 INTRODUCTION
By letter dated April 11, 1996, as supplemented August 23, 1996, Entergy Operations, Inc. (the licensee) submitted a request for changes to the Arkansas Nuclear One, Unit Nos. I and 2 (ANO-l&2), Technical Specifications i
(TSs). The requested changes would allow the implementation of the recently app;oved Option B to 10 CFR Part 50, Appendix J, which allows for a performance-based option for determining the frequency for containment leakage rate testing.
The August 23, 1996, letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination.
2.0 EVALUATION Compliance with 10 CFR Part 50, Appendix J, " Primary Containment Leakage Testing for Water-Cooled Power Reactors," provides assurance that the primary containment, including those systems and components which penetrate the primary containment, do not exceed the allowable leakage rate specified in the TSs and Bases. The allowable leakage rate is determined so that the leakage rate assumed in the safety analyses is not exceeded.
On February 4, 1992, the NRC published a notice in the Federal Reaister (57 FR 4166) discussing a planned initiative to begin eliminating requirements marginal to safety which impose a significant regulatory burden. Title 10 of the Code of Federal Reaulations, Part 50, Appendix J was considered for this initiative and the staff undertook a study of possible changes to this regulation. The study examined the previous performance history of domestic containments and examined the effect on risk of a revision to the requirements of Appendix J.
The results of this study are reported in NUREG-1493,
" Performance-Based Leak-Test Program."
J Based on the results of this study, the staff developed a performance-based approach to containment leakage rate testing. On September 12, 1995, the NRC l
approved issuance of a revision to 10 CFR Part 50, Appendix J, which was l
subsequently published in the Federal Reaister on September 26, 1995, and 9610090368 961003 PDR ADOCK 05000313 P
ppg
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, became effective on October 26, 1995. The revision added Option B,
" Performance-Based Requirements," to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements based on both overall and individual component leakage rate performance.
Regulatory Guide (RG) 1.163, " Performance-Based Containment Leak Test Program," dated September 1995, was developed as a method acceptable to the staff for implementing Option B.
This RG states that the Nuclear Energy Institute (NEI) guidance document, NEI 94-01, Rev. 0, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," provides methods acceptable to the staff for complying with Option B, with the four exceptions described herein.
Option B requires that the RG or other implementation document used by a licensee to develop a performance-based leakage testing program must be included by general reference in the plant TSs. The licensee has referenced RG 1.163 dated September 1995 in the proposed ANO-l&2 TSs.
RG 1.163 specifies an extension in Type A test frequency to at least one test in 10 years based upon two consecutive successful tests. Type B tests may be extended up to a maximum interval of 10 years based upon completion of two consecutive successful tests and Type C tests may be extended up to 5 years based on two consecutive successful tests.
By letter dated October 20, 1995, NEI proposed TSs to implement Option B.
After some discussion, the staff and NEI agreed on the final TSs which were transmitted to NEI in a letter dated November 2,1995. These TSs serve as a model for licensees to develop plant-specific TSs in preparing amendment requests to implement Option B.
In order for a licensee to determine the performance of each component, factors that are indicative of or affect performance, such as an administrative leakage limit, must be established. The administrative limit is selected to be indicative of the potential onset of component degradation.
Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements. Failure to meet an administrative limit requires the licensee to return to the minimum value of the test interval.
Option B requires that the licensee maintain records to show that the criteria for Type A, B, and C tests have been met.
In addition, the licensee must maintain comparisons of the performance of the overall containment system and the individual components to show that the test intervals are adequate. These records are subject to NRC inspection.
l i
l l 3.0 EVALUATION 3.1 ANO-1 Proposed TSs Option B permits a licensee to choose Type A; Type B and C; or Type A, B and C testing to be done on a performance basis. The licensee has elected to perform Type A, B and C testing on a performance basis for AN0-1.
The licensee's application proposes to establish a " Reactor Building Leakage Rate Testing Program," which references RG 1.163, and adds this program as new TS 6.8.4.
The addition of this program requires a change to existing TSs 4.4.1.1, 4.4.1.1.4, 4.4.1.2, 4.4.1.2.5, the TS index, and the associated Bases sections.
The changes proposed by the licensee are in compliance with the requirements of 10 CFR Part 50, Appendix J and consistent with the guidance in RG 1.163.
Despite the different format of the licensee's current TSs, all of the important elements of the guidance provided in the staff's letter to NEI dated November 2, 1995, are included.
However, the licensee has proposed several changes that are in addition to the model TSs or that warrant further discussion.
The action statement of current AN0-1 TS 3.6.1, " Reactor Building," is entered if Type A or Type B and C leakage rates from TSs 4.4.1.1 and 4.4.1.2, respectively, are not within limits.
Current TS 3.6.1 allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reach hot standby from power operation if containment integrity is lost, versus 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in the model TSs. Although the licensee has chosen not to adopt the model TSs, the noted deviation is conservative and is therefore acceptable.
The licensee has proposed not to adopt the individual model TSs for the air lock leakage rates, and has proposed not to include the individual air lock leakage criteria as part of the Reactor Building Leakage Rate Testing Program referenced in new TS 6.8.4.
Instead, air lock leakage rate will be included in the overall Type B and C leakage rate, consistent with the current TSs.
The acceptance criteria located in TS 4.4.1.2.3 states, "the total leakage from all tested penetrations and isolation valves shall not exceed 60% L,."
Section 6.8.4 of the proposed change maintains the requirement for the air locks to be Type B tested with the same acceptance criteria of s 60% L, for the total leakage from all Type B and C tests.
Because the proposed combined Type B and C leakage rates are the same as the current and model TSs, the proposed change is acceptable.
TS 4.4.1.1.1, 4.4.1.1.2, 4.4.1.1.3, 4.4.1.1.5, 4.4.1.1.6, 4.4.1.1.7, 4.4.1.2.1, 4.4.1.2.2, 4.4.1.2.3, 4.4.1.2.4, 4.4.1.3, and 4.4.1.5 will be deleted and the information they contain, where applicable, will be added to the Reactor Building Leakage Rate Testing Program. The deleted TSs contain information concerning the specific conduct of tests, acceptance criteria, I
reporting of results, corrective actions, and visual examinations.
Removal of l
explicit test details and reporting requirements is consistent with the model TSs. Furthermore, visual inspections are now required by proposed TS 4.4.1.1,
_4 and corrective actions are given in current TS 3.6.1.
Since the proposed changes are consistent with the model TSs and do not constitute a failure to adopt or a relaxation of Option B requirements, the staff finds the proposed changes acceptable.
The licensee has proposed deleting parts of the Bases to TS 4.4.1.
These portions contain information regarding the frequency of testing and testing details. This information is now superseded by Option B and therefore no longer applicable or is contained in the Reactor Building Leakage Rate Testing Program.
In its place, text consistent with the model TSs has been added.
Because the propo ad changes remove inapplicable information and are consistent with the model TSs, the proposed changes are acceptable.
The Reactor Building Leakage Testing Program will be added as new TS 6.8.4.
With the exception of not adopting the specific leakage criteria for air locks, the acceptability of which has been discussed in a preceding paragraph, the adopted TSs are consistent with the model. The proposed addition of TS 6.8.4 is therefore acceptable.
3.2 ANO-2 Proposed TSs Option B permits a licensee to choose Type A; Type B and C; or Type A, B and C testing to be done on a performance basis. The licensee has elected to perform Type A, B and C testing on a performance basis for ANO-2.
The licensee's application proposes to establish new TS Section 6.15,
" Containment Leakage Rate Testing Program," which references RG 1.163. The addition of this program requires a change to existing TSs 3/4.6.1.1, 3/4.6.1.2, 3/4.6.1.3.1, 3/4.6.1.3.2, 3/4.6.1.5.3, the TS index, and associated Bases.
The TS changes proposed by the licensee are in compliance with the requirements of 10 CFR Part 50, Appendix J, Option B, and consistent with the guidance in RG 1.163. Despite the different format of the licensee's current TSs, all of the important elements of the guidance provided in the staff's letter to NEI dated November 2, 1995, are included in the proposed TSs.
However, the licensee has proposed several changes that are in addition to the modol TSs or that warrant further discussion.
Thr. action statement for current TS 3.6.1.1, " Containment Integrity," allows F hours to reach hot standby from power operation if containment integrity is lost. The model TSs would allow 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This is a conservative deviation and is therefore acceptable.
The action statement for current TS 3.6.1.2, " Containment Leakage," requires that with containment leakage rates not within limits, restore the leakage rates to within the limits " prior to increasing the reactor coolant temperature above 200*F."
The licensee intends to maintain this wording.
Model TS 3.6.1.1 requires returning containment to operable within I hour, or placing the unit in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within
,s e 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. While the model TSs correct a deficiency in the current TS which do not recognize that containment leakage rates tan be determined during plant operation (Modes 1 through 4), keeping the current TSs is still adequately restrictive.
This is because limiting condition for operation (LCO) 3.0.3 of the current TSs, which is entered when an action of a particular specification cannot be entered because of circumstances in excess of those addressed in the specification, would apply if leakage were determined to be exceeded during plant operations.
LCO 3.0.3 requires initiating action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in hot standby in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in hot shutdown in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in cold shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Because the required actions in the ANO-2 TSs are equivalent to the model TSs, the staff finds this deviation acceptable.
ANO-2 TS 4.6.1.5.3, which requires visual examination of the accessible interior and exterior surfaces of containment, including the liner plate, is being revised.
The current TSs state:
"The structural integrity of the exposed accessible interior and exterior surfaces of the containment, including the liner plate, shall be determined during shutdown for each Type A containment leak rate test (reference Specification 4.6.1.2 by a visual inspection of these surfaces and verifying no apparen)t changes in appearance or other abnormal degradation."
Proposed TS 4.6.1.5.3 would state:
"The structural integrity of the exposed accessible interior and exterior surfaces of the containment, including the liner plate, shall be determined by a visual inspection of these surfaces and verifying no apparent changes in appearance or other abnormal degradation has occurred in accordance with the Containment Leakage Rate Testing Program."
While the proposed format is somewhat different than the model TSs, it preserves the structure of the current TSs and is consistent with RG 1.163.
The staff, therefore, finds the proposed change acceptable.
The Bases for TS 3/4.6.1.5 were changed to reflect the most current maximum containment pressure in the event of a loss of coolant accident. The Bases for TS 3/4.6.1.2 were modified to explain the leakage acceptance criteria and eliminate information regarding low pressure testing of the containment because it is no longer being allowed by Option B.
In addition, a reference to Option B of 10 CFR Part 50, Appendix J, was added for clarity.
The Bases for TS 3/4.6.1.3 were expanded by adding clarifying information and removing the old Bases information that is repetitive. The staff finds these changes acceptable.
3.2 Conclusion The staff has reviewed the changes to both the ANO-l&2 TSs and associated Bases proposed by the licensee and finds that they are in compliance with the requirements of 10 CFR Part 50, Appendix J, Option B, and consistent with the guidance of RG 1.163.
The staff finds the proposed changes acceptable.
4.0 STATE CONSULTATION
In accordance with the Comission's regulations, the Arkansas State official was notified of the proposed issuance of the amendment. The State official had no coment.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change 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 change surveillance requirements. The NRC staff has determined that the amendments involve 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-posed finding that the amendments involve no significant hazards consideration and there has been no public coment on such finding (61 FR 20846).
Accordingly, the amendments meet 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 connection with the issuance of the amendments.
6.0 CONCLUSION
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 be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.
Principal Contributor:
H. Dawson Date: October 3, 1996