2CAN119102, Application for Amend to License DPR-51,applying Guidance of Generic Ltr 88-16 to Remove Cycle Specific Variables from TS & Control Them Under Core Operating Limits Rept

Application for Amend to License DPR-51,applying Guidance of Generic Ltr 88-16 to Remove Cycle Specific Variables from TS & Control Them Under Core Operating Limits Rept

ML20085N159
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/07/1991
From:	Carns N ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20085N162	List: 2CAN119102, Application for Amend to License DPR-51,applying Guidance of Generic Ltr 88-16 to Remove Cycle Specific Variables from TS & Control Them Under Core Operating Limits Rept ML20085N163
References
2CAN119102, GL-88-16, NUDOCS 9111140157
Download: ML20085N159 (7)

Text

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1CAN119102 U. S. Nuclear Regulatory Commission Document Control Desk tiall Station P1-137 Washington, DC -20555

Subject:

Arkansas Nuclear One - Unit 1 Docket. No. 50-313 License No. DPR-51 Cycle 10 Core Operating Limits Report and Propcsed Technical Specification Change Request Per Generic Letter 88-16 Gentlemen:

Generic Letter 88-16 dated October 4,

1988 (OCNA108809), " Removal of Cycle-Specific Parameter Limits from Technical Specifications", encouraged licensees to propose changes to Technical Specifications to control cycle specific pa rame t.c rs under a separate document.

This proposed amendment applies the geldance of Generic Letter 88-16 to remove the Arkansas Nuclear Unit 1

(ANO-1) cycle specific variables from the Technical One Specifications and control them under a new document called the ANO-1 Core Operating I.imits Report.

The proposed ANO-1 Technical Specifications and the ANO-1 Cycle 10 Core Operating Limits Report for the current operating cycle are attached for your review.

In -accordance with 10CFR50.91(a)(1) and using the criteria in 10CFR50.92(c), Entergy Operations has determined that these changes involve no significant hazards consideration.

The basis for these determinations are included in the enclosed submittal.

Although the circumstances of this request are neither emergency nor exigent, prompt review and approval of this proposed amendment is requested prior to startup from cur next refueling outage which is currently scheduled for completion on April 21, 1992.

We request that the license amendment be ef fective upon issuance. This submittal is being made in lieu of a cycle specific submittal for Cycle 11.

A Cycle 11 Core Operating Limits Report will be submitted to the NRC upon issuance.

If you have any further questions, please do not hesitate to contact my staff.

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U.S. NRC November 7. 1991 J

Page:2 Very truly-yours, N7

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N.-S. Carns NSC/sjf Attar.hment cc:

Mr. Robert Martin U.-S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector Arkansas Nuclear One - ANO-1 6 2-Number 1, Nuclear Plant Road Russellv111e, AR 72801 Mr. Thomas W. Alexion NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 11-D-23 One White. Flint North 11555 Rockville Pike Rockville, Maryland 20852 Ms. Sheri Peterson NRR Project Manager, Region IV/ANO-2 U.-S.. Nuclear Regulatory Commission NRR Mail Stop 11-D-23 One' White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Ms. Greta Dicus, Director Division of Radiation-Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72201

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STATE OF ARKAN3AS

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0ATH I,A. W. Yelverton, being duly sworn, subscribe to and say that I am General Manager, Plant Operations ANO for Entergy Operations; that I have

-full authority to execute this oath; that I have read the document numbered ICAN119102 and know the contents thereof; and that to the best of my knowledge, information and belief the statements in it are true.

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verton

~ SUBSCRIBED AND SWORN-TO before me, a Notary Public in and for the County and State above named, this 7M day of 7[suc4*dttL 1991.

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EELQM PROPOSED TECHNICAL SPECIFICATION AND RESPECTIVE SAFETY ANALYSES IN THE MATTER OF AMENDING LICENSE NO, DPR-51 ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO.-50-313

1 f$9 POSED CHANGE 1

The proposed amendment would change ANO-_l Technical Specifications 1.0, 3.5.2.4,:3.5.2.5, 3.5.2.6, Bases of 3.5.2, and 6.12.

Revised copies of the affected pages are included in this attachment.

The following changes are proposed:

a.

Index is_ revised to reflect change.

b.

Section 1.11 is being added to the definitiors section to define the CORE OPERATING LIMITS REPORT.--

c.

Control Rod Group and Power Distribution Limits of -Technical Specification 3.5.2 contain the foll_owing changes:

1.

Section 3.5.2.4 is modified to reference the CORE OPERATING LIMITS REPORT, which will now provide the specified limits to use.

2.

Section: 3.5.2.5 is modified to reference the CORE OPERATING -

LIMITS REPORT, which will provide the control rod position setpoints and the APSR insertion limits.

3.

Section 3.5.2.3 is modified,to reference the _ CORE OPERATING LIMITS rep 0RT. which will provide the reactor power - imbalance setpoints for operation.

4.

Figures - 3.5.2-1 A, page - 48b, through 3,5.2-5, - page 48n will be j

deleted and placed in the CORE OPERATING LIMITS REPORT.

These figures will be exactly the same when placed into the CORE OPERATING LIMITS REPORT.

5.

The Bases for Technical Specification 3.5.2 is modified to reference the CORE OPERATING LIMITS REPORT.

i 6.

Consistent terminology is used for quadrant power tilt limits, reactor power imbalance setpoints, and control rod position setpoints, d.

Section 6.12.3 is being added to reporting requirements to reference the CORE OPERATING LIMITS REPORT.

The pages would be revised as follows:

inmove Insert i

i iv iv y

vi 5b 6

6 47 47 48 48 48a1 48a1 48aa 48b-n 142 142 143 144 145

BACKGROUND Generic Letter 88-16, " Removal of Cycle-Specific Parameter Limits from Technical Specifications", encouraged licensees to remove cycle-specific parameter -limits from their Technical-Specifications and place them in a formal report provided.the limits are developed using an NRC-approved methodology.

This involves addition of an administrative reporting requirement -to submit the formal report on a reload cycle dependent basis and modifications to Technical Specifisations to replace these limits with a reference to the defined formal report.- These proposed changes will, in the-future, remove an unnecessary burden on the licensee and the NRC to prepare and review reload license amendments.

DISCUSSION This amendment request' removes cycle specific core operating limits from the ANO-1 Technical Specifications in a manner consistent with the guidance provided in Generic Letter 88-16.

These proposed changes involve taking Quadrant Power Tilt Limits, Control Rod Position Setpoints, APSR Insertion Limits, Reactor Power Imbalance Setpoints, and LOCA Linear Heat Rate Limits out of the ANO-1 Technical Specifications and Bases and placing them into a formal report.

This report will be called the CORE OPERATING LIMITS REPORT

-(COLR),

These lir its removed from Technical Specifications will not change for the current cycle of operation.

They will only be transferred into the COLR.

The Technical. Specifications that are af fected will refer the user to the : COLR for that particular limit or setpoint when needed.

These limits and setpoints are calculated as a part of the reload report for each cycle for which a 10CFR50.59 review will be performed.

The analytical techniques employed in the analysis have been previously accepted by the Nr* and referenced in the COLR.

Each accident analysis addressed in the ANO-1 Safety Analysis Report (SAR) has been considered in the reload report for a particular cycle.

This is done with respect to changes for any cycle specific parameters to ensure that thermal performance during hypothetical transients is acceptable.

For reload _ modification, the margins of safety for fuel system design, nuclear design, and thermal-hydraulic design are addressed in the reload - report.

The applicable limits and setpoints are determined to be within allowable limits:and requirements for acceptable operation for a particular_ cycle.

The quadrant power tilt limits, control rod position setpoints, and reactor power imbalance setpoints of Technical Specification 3.5.2, and LOCA linear heat rate limits of TS Bases 3.5.2, which will be placed in the COLR, assure that the maximum cladding temperature will not exceed the final acceptence criteria in 10CFR50, Appendix K, assuming worst caso power distribution.

These limits and setpoints were determined using NRC approved codes and methodology, taking into account all perceived uncertainties, worst case conditions and core burnup.

The control rod position setpoints assure hot shutdown by reactor trip under any conditions and ensure that power peaking criteria are not exceeded. These setpoints preclude the insertion of rod groups which could result in any single rod worth greater than the safety analysis assumption for the rod ejection transient.

The physical design and actual rod worths of the control rods have not changed nor has cycle operation.

The simplified gray APSR position limits have been analyzed using worst case conditions and time of core life such that core peaking limits are not violated.

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DETERMINATION OF SIGNIFICANT HAZARQS Entergy Operations has performed an analysis of the proposed change in

-accordance with 10CFR50.91(a)(1)

-regarding no significant hazards consideration using the standards in 10CFR50.92(c)< A discussion of those standards asLthey relate to this amendment request follows:

CIllgrion 1 - Does Not Involve a Significant Increase-in the Probability or Consequences ~ of an Accident Previously Evaluated.

The removal of cycle dependent variables from_ Technical Specifications and placing them into a COLR has no impact on plant operation or safety.

The Technical Specifications-will continue to require operation withiit the core operational limits for each cycle reload calculated by the approved reload design methodologies.

The values or setpoints placed in the COLR are addressed in the Reload Report.

The reload report presents the results of an evaluation of accidents addressed in the ANO-1 SAR.

The evaluation cemonstrates that changes in the fuel cycle design and the corresponding COLR do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated The removal of cycle specific variables would not create the possibility of a new or different kind of accident from any previously analyzed.

The cycle specific variables will continue to-be calculated using NRC approved methods.

This change consists of relocating the cycle specific variables -

from the Technical Specifications to the COLR.

Technical Specifications will continue to require operation within-the required core operatino limits and appropriate actions will be taken if the limits are exceeded.

The Technical Specification changes result in no significant changes to the operation of the unit, friterion 3 - Does Not Involve a Significant Reduction in a Margin of Safety The proposed changesodo not involve a significant reduction in a margin-of safety-since these changes only involve transferring data from-one document to another.

The limits or setpoints themselves will not change until the next fuel cycle.

These values are originally provided in the Reload Report for a particular cycle, The development'of limits for future reloads will continue to conform to methods described in NRC approved documentation.

Each future reload will involve a 10CFR50.59 safety review to. assure that operation of the unit within the cycle specific limits will not involve a significant reduction in a margin of safety.

Therefore, based on the reasoning presented above and the previous discussion of this amendment request, Entergy Operations has determined that the requested changes do not involve a

significant hazards consideration.

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