0CAN109602, Application for Amends to Licenses DPR-51 & NPF-6,reducing Costs for Licensees by Allowing Change to Requirements W/O Necessarily Requiring License Amend,Per GL 95-10
| ML20128L271 | |
| 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 | |
| ML20128L278 | List: |
| References | |
| 0CAN109602, CAN109602, GL-95-10, OCAN109602, NUDOCS 9610110370 | |
| Download: ML20128L271 (8) | |
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- g Entsrgy Operctions, Inc.
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b Ta 501858 488a C. Randy Hutchinson V<r rwh<v a<um m)
October 2,1996 0CAN109602 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station Pl-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 Selected Instrumentation Technical Specifications Allowed By Generic Letter 95-10 Gentlemen:
Attached for your review and approval are the proposed changes to Arkansas Nuclear One Units I and 2 Technical Specifications in accordance with Generic Letter 95-10. This generic letter allows the relocation of selected technical specification instmmentation requirements to licensee controlled documents. The relocation of these requirements will reduce costs for licensees by allowing a change to these requirements without necessarily requiring a license amendment. Relocating these requirements will also reduce NRC staff time by decreasing the number of plant specific changes to the affected technical specifications. The following technical specifications are being affected by this amendment request; Seismic Monitoring Instrumentation, Meteorological Monitoring Instrumentation, Chlorine Detection System, and Turbine Overspeed Protection.
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. The bases for these determinations are included in the attached submittal.
j Entergy Operations requests that the effective date for this change be within 30 days of issuance. Although this request is neither exigent nor emergency, your prompt review is requested.
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9610110370 961002 PDR ADOCK 05000313 P
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U. S. NRC October 2,1996 0CAN109602 Page 2 Very truly yours jg
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t CRII/rdc Attachments To the best of my knowledge and beli f, the statements contained in this submittal are true.
SUBSCRIBED AND SWORN TO hefore me, a Notary Public in and for
[wn County and the State of Arkansas, this 8 day of d:hi/A
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U.S.NRC October 2,1996 0CAN109602 Page 3 l
l cc:
Mr. Leonard J. Callan Regional Administrator 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 1
I ATTACHMENT m
OCAN109602 i
PROPOSED TECHNICAL SPECIFICATION l
AND RESPECTIVE SAFETY ANALYSES i
IN THE MATTER OF AMENDING LICENSE Nos. DPR-51 and NPF-6 ENTERGY OPERATIONS. INC.
ARKANS AS NUCLEAR ONE. UNITS ONE & TWO DOCKET Nos. 50-313 and 50-368 l
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i Attachment to 0CAN109602
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Page1 of4 j
DESCRIPTION OF PROPOSED UNIT 1 CHANGES l
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Relocated specification 3.5.1.10 relating to the chlorine detection system to the Technical l
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Requirements Manual (TRM).
Relocated specification 3.5.1.13 relating to the seismic monitoring instrumentation to the TRM.
l Relocated the bases for the chlorine detection system on page 43b to the TRM.
e Relocated the bases for the seismic monitoring instrumentation and its SAR reference on page 43c to the TRM.
Relocated the chlorine detection system operability requirements on table 3.5.1-1 item 9 on page 45d to the TRM.
Relocated the seismic monitoring instrumentation operability requirements on Table 3.5.1-1 items 14a,14b, and 14c to the TRM and consolidated the remaining functional unit requirements to page 45dl.
Relocated note 27 on Table 3.3.1-1 relating to the seismic monitoring instrumentation operability requirements to the TRM.
Relocated the SR for the turbine overspeed protection system on table 4.1-1 item 31 to the TRM.
Relocated the SR for the seismic monitoring instrumentation on table 4.1-1 item 42 on l
pages 72a and 72b to the TRM.
Relocated the SR for the chlorine detection system on table 4.1-1 item 52 to the TRM.
DESCRIPTION OF PROPOSED UNIT 2 CHANGES l
Revised the index pages to reflect the relocated specifications.
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Relocated specification 3.3.3.3 including the limiting condition for operation (LCO), SR, bases, and tables 3.3-7 and 4.3-5 relating to the seismic monitoring instrumentation requirements to the TRM.
I Relocated specification 3.3.3.4 including the LCO, SR, bases, and tables 3.3-8 and 4.3-4 e
relating to the meteorological monitoring instrumentation requirements to the TRM.
Relocated specification 3.3.3.7 including the LCO, SR, and bases relating to the chlorine detection system requirements to the TRM.
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Attachment to OCAN109602 Prge 2 of 4 Relocated specification 3.3.4.1 including the LCO, SR, and bases relating to the turbine overspeed protection system requirements to the TRM Relocated the requirement in specification 4.7.6.1.2.d,2 for control room automatic I
isolation on a high chlorine test to the TRM Removed the reference from 4.7.12.1.b for specification number for the seismic e
monitoring instrumentation due to specification 3.3.3.3 being relocated to the TRM 4
Removed the fire detection instrumentation bases reference for page B 3/4 3-3 because e
this technical specification (TS) was removed by a previous amendment request.
i Relocated the special reporting requirements associated with TS 6.9.2.b, 6.9.2.c, and e
6.9.2.d to the TRM due to the associated specifications being relocated.
DISCUSSION The NRC issued Generic Letter (GL) 95-10 to allow licensees to relocate certain instrumentation requirements to licensee controlled documents or programs. Relocating these requirements will reduce costs for licensees by allowing them to change these requirements,
without necessarily amending their licenses. The relocation of these requirements will also reduce NRC staff time by decreasing the number of plant specific changes to the affected TS.
The staff has concluded that the specifications listed in the GL were not required to be included in the TS as required by 10 CFR 50.36. The improved standard TS also reflects the staffs position that these requirements do not meet the 10 CFR 50.36 criteria for inclusion in TS. The staff also concluded that the instrumentation addressed in these specifications are not related to dominant contributors to plant risk.
The specifications included in this amendment request are being relocated to the Technical Requirements Manual (TRM). The TRM will be a document that provides a location for those specifications that are no longer deemed appropriate to be included in the TS. The TRM is considered to be a part of the Safety Analysis Report (SAR). Once in the TRM, future changes to these requirements will be controlled under 10 CFR 50.59.
The proposed change is administrative in nature because the instrumentation requirements for the units remain the same. However, the location where these requirements reside and the applicable regulatory requirements for their modification will be different. The proposed change does not represent a change in the configuration or operation of either unit. The proposed change will not affect any plant system or structure, nor will it affect any system functional or operability requirements.
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Attachment to OCAN109602 Page 3 of 4 DETERMINATION OF NO SIGNIFICANT HAZARDS 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:
i Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
The NRC issued Generic Letter (GL) 95-10 to allow licensees to relocate certain instrumentation requirements to licensee controlled documents or programs. The staff has concluded that the specifications listed in the GL were not required to be included in the technical specifications as required by 10 CFR 50.36.
The staff concluded that the instmmentation addressed in these specifications are not related to dominant contributors to plant risk.
The specifications included in this amendment request are being relocated to the Technical Requirements Manual (TRM). Once in the TRM, future changes to these requirements will be controlled under 10 CFR 50.59. By controlling future changes under 10 CFR 50.59, NRC review and approval will be requested for changes exceeding the regulatory threshold of an unreviewed safety question.
i This amendment request does not remove or modify any of the instrumentation requirements i
for either unit. This amendment request does not affect any of the accident initiators, conditions or assumptions for any of the accidents previously evaluated. Therefore, this i
change does not involve a significant increase in the probability of any accident previously evaluated.
This amendment request is administrative in nature and does not affect any system or i
component functional requirements. This change does not affect the operation of the plant or affect any component that is used to. mitigate the consequences of any accident. Therefore, i
this change does n_o1 involve a significant increase in the consequences of any accident j
previously evaluated.
Therefore, this change does apt involve a significant increase in the probability or consequences of any accident previously evaluated.
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Attachment to j
OCAN109602 Page 4 of 4 Criterion 2-Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.
l The relocation of existing requirements from the technical specifications to other licensee controlled documents is considered administrative in nature. This change does not modify or remove any plant instrumentation requirement. The proposed change will not affect 'any plant l
system or structure, nor will it affect any system functional or operability requirements.
Consequently, no new failure modes are introduced as a result of this change. Therefore, this change does aqi create the possibility of a new or different kind of accident from any previously evaluated.
Criterion 3 - Does Not Involve a Significant Reduction in the Margin of Safety.
The proposed amendment request represents a relocation of a portion of the information previously located in each unit's technical specification instrumentation section to other i
licensee controlled documents that are controlled under 10 CFR 50.59. The proposed change is administrative in nature because the instrumentation requirements for the facility remain the same. The proposed change does not represent a change in the configuration or operation of the plant. Therefore, this change does not involve a significant reduction in the margin of safety.
Therefore, based upon the reasoning presented above and the previous discussion of the amendment request, Entergy Operations has determined that the requested change does n_ot involve a significant hazards consideration.
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