ML20207A465

Safety Evaluation Supporting Amend 205 to License NPF-6

ML20207A465
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/19/1999
From:	NRC (Affiliation Not Assigned)
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NUDOCS 9905260347
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UNITED STATES s

.j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30886 4 001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION f

RELATED TO AMENDMENT NO. 205 TO FACILITY OPERATING LICENSE NO. NPF-6 ENTERGY OPERATIONS. INC.

ARKANSAS NUCLEAR ONE. UNIT NO. 2 DOCKET NO. 50-368 i

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1.0 INTRODUCTION

l By application dated August 23,1996 (2CAN089609), as supplemented by letter dated April 9,1999 (2CAN049904), Entergy Operations, Inc. (the licensee), requested changes to the Arkansas Nuclear One, Unit No. 2 (ANO-2) Technical Specifications. The proposed j

amendment would revise Section 5.0, " Design Features," and Section 6.0, " Administrative Controls," of the current Technical Specifications (CTS), adopting for the most part, the form and content of NUREG-1432, Revision 1, " Standard Technical Specifications (STS] for Combustion Engineering Plants" for the changes requested. The proposed changes include the relocation of certain portions of the design features section to other licensee-controlled documents. The relocated requirements will be subject to the appropriate level of regulatory authority and control.

The April 9,1999 (2CAN049904), letter provided clarifying information that did not change the scope of the original application and the initial proposed no significant hazards determination consideration.

2.0 DISCUSSION AND EVALUATION When converting a plant's CTS (or portion thereof) to the STS format, a licensee may, for each individual specification, at its discretion, either (1) adopt the technical requirements of the corresponding STS, or (2) retain the existing CTS, or (3) propose a different specification. The staff classifies selections (1) and (2) as "in-scope." Selection (3) is referred to as "beyond-scope." In-scope changes are generically accepted based on consistency with the staff's policy on STS conversions. Beyond-scope changes are evaluated on an individual basis.

Each of the licensee's proposed changes is discussed and evaluated below, and identified as either "in-scope" or "beyond-scope " Appropriate justification is provided for each beyond-scope change.

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.r 2.1 Uodate of Index Paae 1

Proposed Chanae: Index page XV of the CTS would be changed to reflect the changes to the design features section titles and page numbers consistent with the proposed changes authorized in this amendment.

Evaluation: Administrative (nontechnical) changes that are intended to incorporate human factors principles into the form and structure of the STS so that plant operations personnel can use them more easily are considered in-scope changes and are acceptable on that basis. The index page change is considered in-scope and is, therefore, acceptable.

2.2 Relocation of Unrestricted Areas Fiaure to Offsite Dose Calculation Manual Proposed Chanae: CTS Figure 5.1-3 would be relocated to the Offsite Dose Calculation Manual (ODCM) as Figure 4-2. In addition, CTS 3.11.2.1, CTS 3.11.2.2, CTS 3.11.2.3, CTS 3.11.2.4, and CTS 3.11.2.5 would be modified to refer to Figure 4-2 of the ODCM.

Evduation: This change is no longer applicable as these revisions were already incorporated into the CTS with the issuance of Amendment No.193 on September 23,1998.

2.3 Editorial Chance to CTS 3.11 Prooosed Chanae: In action 'b' of CTS 3.11.1, CTS 3.11.2, and CTS 3.11.3, the word

" specifications" would be changed to its singular form " specification."

Evaluation: This change is no longer applicable as these revisions were already incorporated into the CTSs with the issuance of Amendment No.193 on September 23,1998.

2.4 Exclusion Area Prooosed Chanae: CTS Section 5.1.1 and corresponding Figure 5.1-1," Exclusion Area Boundary," would be replaced with STS Section 5.1, ' Site Location," which provides a text i

description of the location for the site and the Exclusion Area Boundary. CTS Figure 5.1-1 is shown in the Final Updated Safety Analysis Report (UFSAR) as Figure 2.1-2. The site location description was added along with a description of the boundary defining the exclusion area.

The text description of the site location is consistent with the STS format.

Evaluati.QD: The NUREG-1432 guidance recommends inclusion of a text-only description of the sits :stion. The staff has previously found it acceptable to remove figures provided that other figuas or text descriptions contain adequate information pertaining to the site location (See Amendment Nos 204 and 182 for Calvert Cliffs 1 and 2, dated March 14,1995). For ANO-2, the description of the site location provided in STS Section 5.1 contains the equivalent information as provided in CTS Figure 5.1-1. In accordance with 10 CFR 100, the site description includes a minimum distance to the Exclusion Area Boundary to ensure that the area, for which the licensee has the authority to determine all activities including the exclusion or removal of personnel and property from the area, is clearly associated with the " place of use" referred to in Section 182.a of the Act. The inclusion of this map in the UFSAR will ensure that any change to either the boundary or the zone will have to be evaluated using the 10 CFR 50.59 process. Based on the above discussion, the NRC staff finds this proposed

3-change to CTS Section 5.1.1, including the description of the Exclusion Area Boundary, to be acceptable.

2.5 Removal of Section 5.1.2. Includina Associated Fiaure 5.12 Proposed Chanae: Section 5.1.2, " Low Population Zone," and associated Figure 5.1-2 would be removed from the CTS.

Evaluation: CTS Section 5.1.2 defines the Low Population Zone (LPZ) as being shown in CTS Figure 5.1-2.' CTS Figure 5.1-2 depicts the LPZ as a circle centered on the reactor and having a 2.6 statute mile radius. Removal of CTS Section 5.1.2 and associated CTS Figure 5.1-2 is acceptable as this information does not meet any of the inclusion criteria for information contained in Technical Specifications pursuant to 10 CFR 50.36. The staff has previct: sly found it acceptable to remove figures describing the Low Population Zone from the Technical Specifications (See Amendment Nos 204 and 182 for Calvert Cliffs 1 and 2, dated March 14, 1995). The proposed change is consistent with the NUREG-1432 guidance, which does not include an LPZ specification. Therefore, this is considered an in-scope change. A description of the LPZ is currently included in Section 2.1.3.3 of the UFSAR. The existence of this discussion and associated figures in the UFSAR will ensure that any change to either the boundary or the zone will have to be evaluated using the 10 CFR 50.59 process. Based on the above discussion, the NRC staff has concluded that the proposed change is acceptable.

2.6 Containment - Confiauration. Desian Pressure. And Desian Temoerature Proposed Chanae: Section 5.2, " Containment," would be removed from the CTS. The design features that are currently listed in this section are either duplicated in or will be added to the UFSAR. The following sections of the UFSAR contain similar containment design requirements; Section 12.1.2.5, Table 6.2-7, Table 1.3-1, Figure 1.2-5, Figure 3.81, Figure 3.8 2, Figure 3.8-5, Figure 3.8-7, and Figure 3.8-8. The minimum thickness of the concrete floor at the containment sump is the only information contained in CTS Section 5.2 that is not currently described in the UFSAR. The licensee has committed to update the UFSAR with this information once the amendment has been approved.

Evaluation: CTS 5.2 specifies the following containment design features: shape, material of construction, nominal inside diameter, nominal inside height, minimum thickness of concrete walls, minimum thickness of concrete roof, minimum thickness of concrete floor pad, minimum thickness of concrete floor at the sump, nominal thickness of steel liner, net free volume, design pressure, and design temperature. The licensee proposes the elimination of CTS Section 5.2.

However, certain modifications or alterations to the containment would have a significant impact on plant safety and therefore they are required to be controlled by Technical Specifications. It is noted that accounting for such changes is already adequately controlled by the containment limiting conditions for operation in CTS Section 3/4.6 for ANO-2 and need not be specified in the design features section. Elimination of this information from the design features section has been previously approved by the staff on the basis that this information does not meet any of j

the inclusion criteria specified in 10 CFR 50.36 (See Amendment Nos 204 and 182 for Calvert Cliffs 1 and 2, dated March 14,1995). Further, the information contained in CTS Section 5.2, which is to be eliminated by this proposed change, is presently in the UFSAR with the above noted exception of the minimum thickness of the concrete floor at the containment sump. A license condition has been established to ensure that the value for the minimum thickness of

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. the concrete floor at the containment sump is added to the UFSAR for ANO-2. Modifications or alterations to those design features as described in the UFSAR are controlled under the 10 CFR 50.59 change process. The NUREG-1432 guidance does not recommend the inclusion of containment configuration specifications in the Design Features Section of the STS. Therefore, I

this change is considered in-scope. Based on the above discussion, the staff finds the proposed change to CTS Section 5.2 acceptable.

2.7 Reactor Core Proposed Chanae: CTS Section 5.3.1, " Reactor Core - Fuel Assemblies," would be replaced l

with a proposed new writeup as STS Section 5.2.1. The new writeup includes the following changes from CTS Section 5.3.1:

a.

The maximum enrichment of 2.99 weight percent U-235 for the initial core loading would be deleted. Enrichment limitations for subsequent and current fuelloadings l

is controlled by CTS 3.9.12.

b.

The limit of 2114 grams of uranium for ecch fuel rod have been deleted. The licensee has committed to add this information to the UFSAR for ANO-2.

l c.

The maximum limit of 236 fuel rods per assembly and the nominal active fuel length of 150 inches have been deleted. These requirements are currently described in the UFSAR for ANO-2.

d.

The option of using ZlRLO clad fuel rods in addition to the Zircalloy clad fuel rods would be added, consistent with the STS. ZlRLO is a zirconium based alloy that has been previously accepted by the NRC in 10 CFR 50.44 and would facilitate its future potential use by ANO-2. The current fuel cladding is described as Zircalloy-4 l

in UFSAR Section 4.2.1.2 and would therefore, require a UFSAR change and 10 CFR 50.59 evaluation to allow the use of the ZlRLO cladding.

e.

A statement would be added stating, " Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and i

methods and shown by tests or analyses to comply with all fuel safety design bases."

1 f.

A statement would be added stating, "Other cladding material may be used with an approved exemption." (This will allow the use of other cladding material without requiring a TS amendment. However, an exemption to the Code of Federal Reaulations would be required, ensuring that the NRC has approved the use of other cladding materials. The I

use of any cladding material other than Zircalloy-4 would require an UFSAR change and a 10 CFR 50.59 evaluation to allow its use.)

Evaluation: CTS Section 5.3.1 lists some of the design features associated with the initial core loading for ANO-2. This CTS states that," Reload fuel shall be of a low enrichment and similar in physical design to the initial core loading." ANO-2 is currently in fuel cycle No.14. In item a, CTS Section 5.3.1 lists a maximum enrichment level of 2.99 weight percent U 235 for the initial core. CTS 3.9.12, " Refueling Operations - Fuel Storage," specifies a maximum fuel enrichment of 5.0 weight percent U-235 for new and spent fuel. Therefore, it is acceptable to delete l

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. references to fuel enrichment from CTS Section 5.3.1 as this parameter is currently controlled by CTS Section 3.9.12. Information discussed in items b and c will be deleted from the Technical Specifications as this information does not meet any of the inclusion criteria specified in 10 CFR 50.36. The licensee has committed to adding a discussion of maximum uranium weight per fuel rod of 2114 grams to the UFSAR. A license condition has been established to ensure that the UFSAR is appropriately updated. The information discussed in Item c currently exists in the UFSAR. Modifications or alterations to these design features as described in the UFSAR are controlled under the 10 CFR 50.59 change process which provides the appropriate regulatory control. The change discussed in item d promotes consistency between the ANO-2 TSs and 10 CFR 50.44, which allows the use of ZlRLO. ZlRLO is a zirconium-based alloy that has been previously accepted by the NRC in 10 CFR 50.44 and would facilitate its future potential use by ANO-2. The current fuel cladding is described as Zircalloy-4 in UFSAR Section 4.2.1.2 and would therefore require an UFSAR change and a 10 CFR 50.59 evaluation to allow the use of the ZlRLO cladding. The proposed replacement " Fuel Assemblies" specification, discussed in item e, is consistent with the staff's NUREG-1432 guidance, and, thus, in-scope, with the exception of item f, which is a beyond scope issue. However, the NRC staff has previously evaluated and approved Item f in the " Fuel Assemblies" specification for similar facilities (i.e., Palo Verde amendments issued March 6,1996). The proposed beyond-scope change is acceptable on the basis that the exemption application and review process provide adequate controls and require NRC approval prior to implementation. The requirements discussed under items e and f are additions to the CTS. Based on the above discussion, the NRC staff finds that this proposed change is acceptable.

2.8 Control Element Assemblies Proposed Chanae: CTS Section 5.3.2," Control Element Assemblies," would be relocated within the TSs and be renumbered as STS Section 5.2.2," Control Element Assemblies." The proposed change would list the site-specific number of control element assemblies along with their material of construction.

Evaluation: This change is consistent with the staff's NUREG-1432 guidance, and, thus, is considered an in scope change. The discussion of the site-specific number of control element assemblies for the proposed change is idental to that which is described in the CTS. As such, this change is purely an administrative effort to renumber the TS. The addition of the material of construction for the control element assembly is a more restrictive change that ANO-2 accepted to provide additionalinformation to be consistent with the STS. The NRC staff finds that the proposed change is in scope and is acceptable.

o. 9 Reactor Coolant System (RCS) Desian Pressure and Temoerature Proposed Chanae: CTS Section E.4.1, " Reactor Coolant System (RCS) - Design Pressure and Temperature," would be removed from the CTS, which is consistent with the staff's NUREG-1432 guidance for the STS.

Evaluation: This section of the CTS will be deleted because other areas of the CTS adequately control reactor coolant system parameters, such as; temperature, pressure, and boundary degradation, which could have a significant impact on safety. CTS 3.2.6 and 3.2.8 provide effective operational limits to ensure RCS temperature is maintained below its design limit.

CTS 3.2.8 and 3.4.2 provide effective operational limits to ensure RCS pressure is maintained i

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L below design limit. Additionally, CTS 3/4.4 provides the adequate controls required to monitor RCS degradation. Therefore, CTS Section 5.4.1 can be eliminated from the Technical Specifications as this information does not satisfy any of the inclusion criteria specified in 10 CFR 50.36. In addition, design-basis information is also contained in the UFSAR such that these requirements are maintained under the 10 CFR 50.59 process and are, therefore,

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adequately controlled. The proposed change is consistent with the staff's NUREG 1432 guidance, and, thus, is considered an in-scope change. Therefore, the NRC staff has cr.,ncluded that this change is acceptable.

2.10 RCS Desian Volume Proposed Chanae: CTS Section 5.4.2, " Reactor Coolant System (RCS) - Design Volume,"

would be removed from the CTS, which is consistent with the staff's NUREG-1432 guidance for l

the STS.

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Evaluation: The requested change is no longer required. CTS Section 5.4.2 has already been i

deleted from the TSs under Amendment No.181. No further review of this issue is required.

2.11 Meteoroloaical Tower Location i

Prooosed Chanae: CTS Section 5.5, " Meteorological Tower Location," and associated CTS Figure 5.1-1 would be removed from the TS.

l Evaluation: UFSAR Section 2.3.3.1.1 currently describes the meteorological tower and its location. The meteorological tower is also shown on UFSAR Figure 2.1-3 in a manner identical to the CTS. Location of these requirements to the UFSAR provides an acceptable level of l

regulatory oversight as the control of this information is governed by the 10 CFR 50.59 change l

process. The proposed change is consistent with the staff's NUREG-1432 guidance, and, i

thus, is considered an in scope change. CTS Section 2.3.3.1.1 can be eliminated from the CTS as this information does not satisfy any of the inclusion criteria established in 10 CFR 50.36 and is therefore not required to be located in the Technical Specifications. Therefore, the NRC staff has concluded that this change is acceptable.

2.12 Soent Fuel Storaae Criticality Proposed Chanae: CTS 5.6.1.1, " Criticality - Spent Fuel," would be expanded to include the intended information recommended in the staff's NUREG-1432 guidance explicitly or through 3

reference to another part of the CTS. The CTS includes a k, limitation with the pool flooded i

l with unborated water. The proposed change includes this requirement and references UFSAR I

Section g.1 for the uncertainties associated with the evaluation. In addition, the proposed change adds the nominal center-to-center distance between fuel assemblies in the storage racks from UFSAR Figure 9.1-12A and cross references the fuel storage requirements in CTS 3.9.12.

Evaluation: The proposed change provides the information recommended in the staff's NUREG-1432 guidance for STS through explicit requirements or by reference to other areas of the CTS for the site-specific conditions at ANO-2. NUREG-1432, STS 4.3.1.1, " Fuel Storage -

Criticality, ltems a, e, and f are satisfied through reference to CTS 3.9.12. The licensee indicated that when it performs the complete conversion to the STS, this cross reference will be l

. reevaluated to determine the best presentation of this information. The NRC staff has concluded that the requirements of CTS 3.9.12 are sufficient and meet the intent of the STS for i

the site-specific conditions at ANO-2. NUREG-1432, STS 4.3.1.1, " Fuel Storage - Criticality,"

Items b, c, and d are satisfied through explicit instructions in the proposed change. Items c and j

d make a distinction between high and low density storage racks and their respective center-to-center spacing. The ANO 2 spent fuel pool has one center-to-center spacing for the entire pool. Therefore, the distinction between high and low density racks provides no useful information in this area and has been combined and condensed in the proposed change. The proposed change is more restrictive then the CTS with the addition of the center-to-canter spacing requirement. In addition, the information provided in STS 5.3.1 is consistent with the intent of the information recommended in NUREG-1432, STS 4.3.1.1, " Fuel Storage -

Criticality," and is considered an in-scope change. The information contained in the proposed change is adequate for the storage control of spent fuel in the ANO-2 spent fuel pool.

2.13 New Fuel Storaae Rack Criticality l

Prooosed Chanae: CTS 5.6.1.2,"New Fuel Storage Rack Criticality," requirements would be i

revised to reflect the recommendations in the staff's NUREG-1432 guidance, which is consistent with the STS format. The licensee has committed to add the allowance for uncertainties associated with the k, analysis to the UFSAR. The site-specific nominal distance between new fuel assemblies in the storage racks would be specified. The site-specific maximum enrichment of 5.0 weight percent, and 26-inch center-to-center distance requirement is included as approved in Amendment No.178.

Evaluation: This change to the ANO-2 new fuel storage requirements in the CTS is consistent with the STS. This change reformats the existing ir: formation to match the STS format. No technicalinformation has been altered by this change. The proposed change is consistent with the staff's NUREG-1432 guidance, and, thus, is considered an in-scope change. Therefore, the NRC staff has concluded that this change is acceptable.

2.14 Fuel Storace Drainaae Section Proposed Chanae: CTS 5.6.2, " Fuel Storage - Drainage," would be moved to proposed STS Section 5.3.3. The content of this section would remain in tact such that this change was limited to renumbering for consistency with the other changes discussed in this amendment.

Evaluation: The requirements are moved but unchanged. The proposed change is consistent with the staff's NUREG-1432 guidance, and, thus, is considered an in-scope change.

Therefore, the NRC staff has concluded that this change is acceptable.

2.15 Fuel Storaae Caoacity Section Proposed Chanae: CTS 5.6.3, " Fuel Storage - Capacity," would be moved to proposed STS Section 5.3.4. The content of this section would remain in tact such that this change is limited to renumbering for consistency with the other changes discussed in this amendment.

Evaluation: The requirements are moved but unchanged. The proposed change is consistent with the staff's NUREG-1432 guidance, and, thus, is considered an in-scope change.

Therefore, the NRC staff has concluded that this change is acceptable.

. 2.16 Component Cvelic or Transient Limits Prooosed Chanae: The Component Cyclic or Transient Limits, CTS 5.7.1, along with the associated CTS Table 5.7-1 would be deleted from the CTS. The RCS design transients are described in Section 5.2.1.5 of the UFSAR. The CTS cyclic or transient limits that are currently not in the UFSAR will be added. STS Section 6.8.4 will be added to establish a Component Cyclic or Transient Limit Program. This program will be relocated in accordance with the STS.

CTS 6.10.2.e record retention requirements for the transient or operational cycles will remove the reference to CTS Table 5.7-1 and insert a reference to the Component Cyclic or Transient

~ Limit Program. Record retention requirements will be placed in the UFSAR.

Evaluation: The proposed change will relocate the requirements from the Component Cyclic or

~ Transient Limits in the CTS to the UFSAR. The licensee has committed to update the UFSAR as required to relocate this program without changes to its requirements. A license condition has been establish to ensure that the UFSAR is updated appropriately. In addition, CTS Section 6.0, " Administrative Controls," will be updated to reflect the requirement to have the program and the record retention requirements associated with this change. STS Section 6.8.4 has been modified to reflect the Component Cyclic or Transient Limits Program requirement.

STS Section 6.10.2.e has been revised to reflect record retention requirements associated with this program. The 10 CFR 50.59 change process provides sufficient regulatory control over this program after its relocation. The staff has previously found it acceptable to remove Component Cyclic or Transient Limits from the Technical Specifications (See Amendment Nos 204 and 182 for Calvert Cliffs 1 and 2, dated March 14,1995) since this information does not satisfy any of the inclusion criteria specified in 10 CFR 50.36. The proposed change is consistent with the staff's NUREG-1432 guidance, and, thus, is considered an in-scope change. Therefore, the NRC staff has concluded that this change is acceptable.

3.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Arkansas State official was notified of the proposed issuance of the amendment. The State official had no comments.

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4.0 ENVIRONMENTAL CONSIDERATION

1 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. 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 Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding

' (61 FR 52965, October 9,1996). This amendment also changes recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

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5.0 CONCLUSION

The Commission 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 l

operation in the proposed manner, (2) such activities will be conducted in compliance with the

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Commission's regulations, and (3) the issuance of the amendment will not be inimical to the l

common defense and security or to the health and safety of the public.

l Principal Contributors: C. Nolan Date:

May 19, 1999 l

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