2CAN010505, Arkansas, Unit 2 - License Amendment Request Proposed Technical Specification Change to Relocate Containment Overcurrent Protection Devices from the ANO-2 Technical Specifications

Arkansas, Unit 2 - License Amendment Request Proposed Technical Specification Change to Relocate Containment Overcurrent Protection Devices from the ANO-2 Technical Specifications

ML050330167
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/31/2005
From:	Forbes J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN010505
Download: ML050330167 (16)

Text

Entergy Operations, Inc.

Enty God 1448SR 333 EIte M yVRussellville. AR 72802 Tel 479-8584888 Jeffery S. Forbes Vice President Operations ANO 2CAN010505 January 31, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request Proposed Technical Specification Change to Relocate Containment Overcurrent Protection Devices from the ANO-2 Technical Specifications Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

Dear Sir or Madam:

Attached for your review and approval are proposed Technical Specification (TS) changes revising the requirements associated with Arkansas Nuclear One, Unit 2 (ANO-2) containment overcurrent protection devices. Pursuant to 10 CFR 50.90, Entergy hereby proposes to amend Operating License NPF-6 to eliminate Technical Specifications 3.8.2.5, ELECTRICAL POWER SYSTEMS - Containment Penetration Conductor Overcurrent Protective Devices. The proposed change will relocate the requirements for containment penetration conductor overcurrent protective devices to the Technical Requirements Manual. Attachment 1 provides the Analysis of Proposed Technical Specification Change. Attachment 2 provides the marked-up version of the appropriate pages of the current Technical Specifications.

Entergy will modify the Table of Contents and the Bases for these Technical Specifications under the ANO-2 Bases Control Program. Attachment 3 provides the marked-up version of the appropriate pages of the Table of Contents and the Technical Specifications Bases for information.

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. A new commitment is being made as discussed in Attachment 4.

The proposed change is neither exigent nor emergency; however, your prompt review is requested. Once approved, the amendment shall be implemented within 60 days. If you have any questions or require additional information, please contact Steve A Bennett at 479-858-4626.

A6 DI

2CAN01 0505 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on January 31, 2005.

Sincerely, JSF/sab Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. Proposed Technical Specification Bases Changes (mark-up). For Information Only

4. List of Regulatory Commitments cc: Dr. Bruce S. Mallett 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. Box310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Drew Holland MS 0-7D1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205

i Attachment I 2CANOI 0505 Analysis of Proposed Technical Specification Change to 2CAN01 0505 Page 1 of 5 Analysis of Proposed Technical Specification Change

1.0 DESCRIPTION

OF PROPOSED CHANGES Entergy proposes to amend Operating License NPF-6 by relocating Specification 3.8.2.5, ELECTRICAL POWER SYSTEMS - Containment Penetration Conductor Overcurrent Protective Devices from the Technical Specifications (TSs) of Arkansas Nuclear One, Unit 2 (ANO-2) to the Technical Requirements Manual (TRM).

2.0 PROPOSED CHANGE

The proposed changes will relocate the requirements for containment penetration conductor overcurrent protective devices from the ANO-2 TSs to the ANO-2 TRM, a licensee controlled document. The information contained in the associated Bases will also be relocated to the TRM. The proposed changes will not adversely affect the operation of this equipment and the functions it performs. Changes to the TRM are controlled in accordance with 10 CFR 50.59.

Revisions to the Bases and Table of Contents for these Technical Specifications are being provided for information only.

3.0 BACKGROUND

The ANO-2 Technical Specifications are formatted to the Standard Technical Specification for Combustion Engineering designed plants. TS 3.8.2.5 was contained in the TSs issued by the NRC during the initial operating license. Even though modified, Entergy has retained the control of the containment overcurrent protection devices in the TSs from initial issuance to the present. NUREG-1432, Revised Standard Technical Specifications Combustion Engineering Plants does not contain a Limiting Condition for Operation for containment overcurrent protection. Therefore, Entergy is proposing to remove these protective devices from the TSs consistent with that allowed by the revised standard technical specifications.

4.0 TECHNICAL ANALYSIS

10 CFR 50.36c(2)(ii) contains the requirements for items that must be in Technical Specifications. This regulation provides four (4) criteria that can be used to determine the requirements that must be included in the Technical Specifications. Items not meeting any of the four criteria can be relocated from Technical Specifications to a licensee controlled document. The Licensee can then change the relocated requirements, if necessary, in accordance with 10 CFR 50.59. This should result in significant reductions in time and expense to modify requirements that have been relocated while not adversely affecting plant safety. The criteria and an evaluation of ANO-2 Technical Specification 3.8.2.5 proposed for relocation are provided below.

The containment penetration conductor overcurrent protective devices are installed to minimize the damage from a fault in a component inside containment or in cabling which penetrates containment. This prevents an electrical penetration from being damaged in such a way that the containment structure could be breached.

to 2CAN01 0505 Page 2 of 5 Criterion I - Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

This criterion addresses instrumentation installed to detect excessive Reactor Coolant System (RCS) leakage. Technical Specification 3.8.2.5, which addresses the containment penetration conductor overcurrent protective devices, does not cover installed instrumentation that is used to detect, and indicate in the control room, a significant degradation of the reactor coolant pressure boundary.

This requirement does not satisfy Criterion 1.

Criterion 2 - A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation. This criterion also includes active design features (e.g., high pressure/low pressure system valves and interlocks) and operating restrictions (pressure/temperature limits) needed to preclude unanalyzed accidents and transients.

The containment penetration conductor overcurrent protective devices do help preserve the assumptions of the accident analysis by enhancing proper equipment operation. However, they are not a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The containment penetration conductor overcurrent protective devices do not satisfy Criterion 2.

Criterion 3 - A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The purpose of this criterion is to capture only those structures, systems, and components that are part of the primary success path of the safety analysis (an examination of the actions required to mitigate the consequences of the design basis accidents and transients). The primary success path of a safety analysis consists of the combinations and sequences of equipment needed to operate, so that the plant response to the design basis accidents and transients limits the consequences of these events to within the appropriate acceptance criteria. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function, but it does not include backup and diverse equipment.

The containment penetration conductor overcurrent protective devices are installed to minimize the damage from a fault in a component inside containment, or in conductors which penetrate containment. However, the containment penetration conductor overcurrent protective devices are not a structure, system, to 2CAN010505 Page 3 of 5 or component that is part of the primary success path and which functions or actuates to mitigate a design bases accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The containment penetration conductor overcurrent protective devices do not satisfy Criterion 3.

Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The purpose of this criterion is to capture only those structures, systems, and components that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Requirements proposed for relocation do not contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk.

The containment penetration conductor overcurrent protective devices are not a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to the public health and safety.

The Maintenance Rule (10 CFR 50.65) does not require these protective devices to be monitored for unavailability. In addition, a review of industry operating experience did not produce any examples where containment penetration breakers have had a significant adverse effect on public health and safety. The containment penetration conductor overcurrent protective devices do not meet Criterion 4.

The requirements contained in this specification for the containment penetration conductor overcurrent protective devices do not meet any of the 10 CFR 50.36c(2)(ii) criteria for items that must be in Technical Specifications. Therefore, the Technical Specification requirements can be relocated.

The Bases for Technical Specifications 3.8 associated with containment penetration overcurrent protection will be relocated to the TRM to reflect the proposed changes to the respective specifications. The proposed changes will not result in any changes to the design basis of the protection devices.

5.0 REGULATORY ANALYSIS

5.1 ANO-2 Final Safety Analysis Report (FSAR)

Section 8.3.1.2.4 of the ANO-2 FSAR discusses the level of compliance with Regulatory Guide (RG) 1.63, Electrical Penetration Assemblies in Containment Structures for Nuclear Power Plants. As discussed the ANO-2 penetrations meet the requirements of IEEE 317-1971 and were not originally required to meet RG 1.63. The primary and backup protective devices protect the penetration conductors against maximum short circuit conditions as defined by IEEE 317-1971. This FSAR section goes on to state that the Technical Specifications require that the trip setpoints of the primary and backup breakers be checked periodically.

to 2CAN01 0505 Page 4 of 5 The removal of these protection devices from the ANO-2 Technical Specifications will in no way change the design and licensing basis of ANO-2 and its compliance to the discussion provided in the FSAR. However, the sentence in the FSAR referencing the TSs will be removed upon NRC approval of this amendment.

5.2 Determination of No Significant Hazards Consideration Entergy Operations, Inc. is proposing that the Arkansas Nuclear One Unit 2 (ANO-2)

Operating License be amended to revise the requirements for ensuring containment structural integrity. The proposed change will relocate the requirements for containment penetration conductor overcurrent protective devices from Technical Specification 3.8.2.5 to the Technical Requirements Manual (TRM).

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:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes to relocate the requirements for containment penetration conductor overcurrent protective devices from Technical Specifications to the TRM will have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design basis accidents will not change. Operation of the containment penetration conductor overcurrent protective devices is not an accident initiator and can not cause an accident. Whether the requirements for the containment penetration conductor overcurrent protective devices are located in Technical Specifications or the TRM will have no effect on the probability or consequences of any accident previously evaluated.

Therefore, the removal of overcurrent protection devices from the TS does not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed changes to relocate the requirements from Technical Specifications to the TRM will not alter the plant configuration (no new or different type of equipment will be installed) or require any new or unusual operator actions. The proposed changes will not introduce any new failure modes that could result in a new accident.

Also, the response of the plant and the operators following the design basis accidents is unaffected by the changes.

Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated.

to 2CAN010505 Page 5 of 5

3. Does the proposed change involve a significant reduction in a margin of safety?

The proposed changes will relocate the requirements for containment penetration conductor overcurrent protective devices from Technical Specifications to the TRM.

Any future changes to the relocated requirements will be in accordance with 10 CFR 50.59 and approved station procedures. The proposed changes will have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design basis accidents will not change. In addition, the relocated requirements do not meet any of the 10 CFR 50.36c(2)(ii) criteria on items for which Technical Specifications must be established.

Therefore, this change does not involve a significant reduction in the margin of safety.

Based upon the reasoning presented above and the previous discussion of the amendment request, Entergy Operations has determined that the requested change does not involve a significant hazards consideration.

5.3 Environmental Considerations The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to record keeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 PRECEDENCE The proposed change is similar to that submitted by Dominion Generation (formerly Northeast Nuclear Entergy) on April 19, 2000 for the Millstone Nuclear Power Station, Unit 3. The NRC approved the proposed amendment on January 16, 2001.

Attachment 2 2CANOI 0505 Proposed Technical Specification Changes (mark-up)

ELECTRICAL POWER SYSTEMS GONTAINMENT PENETRATION CONDUCTOR OVE-RGU NT- PROTE-GIVE-E-EVIGES LIMITING CONDITION FOR OPERATION 3.8.2.5 Primary and backup containment penetration conductor eveFGuFrent protective devices associated with each containment electrical penetration circuit shall be OERBLE. The SCOpe of these protective-dewieseXoludesthose-GURits forFwhich Gcedible fault currents would not exceed the clectrica'penetfation design Faing, APPLICABILITY: MODES 1, 2, 3 and 4.

AGTION:

_r-X_ ___ _l . _ is _ _

devices one or more ot-The containment penetration conauctor overcurrent-roteetive A! _ _ _ _ _ Us-. __ al _. _ _

WOth ____ _s ___s_

innnpe~abne4

a. De energize the circuit(s) by tripping the aSsoGiaed baokup GiGU"breaker within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and verifying the backup circuitbfreakeobeFipped-at-feast-once pe 7 days thereafter, or

b. Be in at least HOT STANDBY within 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 following 30 houfs.

SURVEILLANGE REQ MOdhMENTS

.. 8.2.5 All containment peRetratiorn rcndUctorF veFrGrr-eRt-PteGtivedevices shall be demonstrated OPERABLE in accordance with the manufacturers' recommendations:

a. At least-once-per 18 mnths:

1. ForatWleast one 6.9 kv reactor cootant-pump-Giuit, such that allaGtor coolant PUMP ciruits aRnd their aSSOciated baGup- Fuits-are-demenstrated OPERABLE at least each 72 months, by performance of:

(a) A CHANNEL CALIBRATION ofthe assoCiated-pirteGtive F lays-apd (b) An integrated system functional est-which inoludes rimulated-automatic aotuatieof the system and verifying4hat-eaoh relay-aRd-assooiated GifGuit breakers and control circuits functioP-as-designed

2. For each type of 480 volt air frame protcotive device, such that all 480 volt aif frame protective devices are demonstFated OPERABLE-atleast-ORGe eaGhNX 18 months, w.here N is the number of devGes-ef-each type, by penorrmane of (a)- A rabrati o-ef the proteotive relays-v-deViGesthat-aFe actuated-by protective relays which includes verifiratn oftherangeaour-asy-and alaFrMAtriD Gnability. and

-ARKANSAS -- UNIT 2 ! UI 2 1 Amendment m31 No. 35,134,146,208 I

ELECTRICAL POWER SYSTE-MS SURVEILLANCE REQUIREMENTS (Continued)

(b) A functional test of protective devices that are actuated by protective relays which verifies that the protective device trips when its associated-protective relays actuate, and (c) A functional test which consists of injeGti rary current-in each Gvercurrent element mounted on the poteitive deVice at-he speGified 6etpOint and verifying that the proterfive~evice trips-whencah oveFGFent element actuates. if any Protective deViaefails to funotiopas designed, a other protective devices of the same type ehall be tested.

3. For molded case protective devices, such that-a-pretective devies oGfeah type-are demonstrated OPERABLE at least oRGe eaGh N x 18 mGRths, wheF is-the number of devices of each type, by performanceeof (a) A functional test of at least one protertive-devie f-eaoh type whioh consists of injection of primary current at the specified setpoint to the protective device and verifying that the protective device trips when the oveFcUrrent elements are actuated. f any protective device fails to fuRtion as deSigRned, all other prFtective deVices of-the-same trypehal be tested.

b. At least-one per60months-by pe orarrngi Spi---onsan@-peventive maintenanGe on eaGh protective device in accordance with procedures pnepared in GonjUrGtiGn with its manufacturersr-ecommnRdations-r A .- ,11 A .i- I. .-- . ..

1K1 O -E 1. - I A ____l K1_ en At iNPONNOMO UNM ea' O/t-1id /MFeRUF:ent N4. B.

Attachment 3 2CAN01 0505 Proposed Technical Specification Table of Contents and Bases Changes (mark-up)

For Information Only

LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. Distribution - Operating .3/4 8-6 A.C. Distribution - Shutdown .3/4 8-7 D.C. Distribution - Operating .3/4 8-8 D.C. Distribution - Shutdown .3/4 8-10 Containment Penetration Conductor Overcurrent Protective Devices 3/14 8 11 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION .3/4 9-1 3/4.9.2 INSTRUMENTATION .3/4 9-2 3/4.9.3 DECAY TIME AND SPENT FUEL STORAGE .3/4 9-3 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS .3/4 9-4 3/4.9.5 COMMUNICATIONS .3/4 9-6 3/4.9.6 REFUELING MACHINE OPERABILITY .3/4 9-7 3/4.9.7 CRANE TRAVEL - SPENT FUEL POOL BUILDING .3/4 9-8 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION .3/4 9-9 3/4.9.9 WATER LEVEL - REACTOR VESSEL .3/4 9-10 3/4.9.10 SPENT FUEL POOL WATER LEVEL ....................................................... 3/4 9-11 3/4.9.11 FUEL HANDLING AREA VENTILATION SYSTEM ................................... 3/4 9-12 3/4.9.12 FUEL STORAGE ............................................................. 3/4 9-14 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN .......................... ................................... 3/4 10-1 3/4.10.2 GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS.... 3/4 10-2 3/4.10.3 REACTOR COOLANT LOOPS ............................................................. 3/4 10-3 ARKANSAS - UNIT 2 IX Amendment No. 29,60 Rev.

3/4.8 ELECTRICAL POWER SYSTEMS BASES TS 3.8.1.1 Action "c.4" is entered when one of the inoperable A.C. Sources is restored to an OPERABLE status as required by Action "c.3" and requires restoration of the remaining inoperable A.C. Source to an OPERABLE status. The allowable restoration time in Action "c.4" for the remaining inoperable A.C. source began when the component initially became inoperable.

If not restored within the AOT, then a plant shutdown is required. The requirement associated with the AACDG (reference Action ub.3" Note 1) is applicable to the EDG AOT.

TS 3.8.1.1 Action "e.3" requires restoration of the remaining inoperable EDG to an OPERABLE status. The time allowed for restoration is based on the time at which the remaining inoperable EDG was initially declared inoperable. If not restored within the AOT, then a plant shutdown is required. The requirement associated with the AACDG (reference Action "b.3," Note 1) is applicable to the EDG AOT.

TS 4.8.1.2.c.3 demonstrates the EDG load response characteristics and capability to reject the largest single load without exceeding predetermined voltage and frequency while maintaining a specified margin to the overspeed trip. For ANO-2, the single load for each EDG is the Service Water pump, rated at 800 HP (636.9 KW).

Containment e!ectrical penetrations and penetration conductors are protected by either de enrieng c-;iGits-~ t required during reartor operationorz-by demnstfating the OPERABI.ITY of-priomaF-and baeup overurrent- pvtection circuit breaker&-during periodicG 6uveilanoe The 480 volt air-fagme-preteotive devices utilize clectro mechanical-everourent clerents Which are meunted op,4he pretetive deviGc and,in 6ome i qmtaPGes-,pretective relays to tip4he-prtetive devioe. Aotuationof theoverolurent element or relay w..ill trip4he-protective deVice. The molded case protcstive devices utilize magnetic or thermal-manetiGeverntrrent elements which are contained in the protective device. Actuation of each overcurrent element will trip the proteGtive de~ioe.

TS 3.8.2.3 Action Vb" requires the performance of SR 4.8.2.3.a.1 within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter for a loss of one of the required full capacity chargers. If any Category A limit in Table 4.8-2 is not met while a charger is inoperable, the associated battery bank shall be declared inoperable and ACTION "a" entered. The Category A limits in Table 4.8-2 specify the normal limits for electrolyte level, float voltage and specific gravity for each designated pilot cell. When TS 3.8.2.3 ACTION UbV is entered without the associated battery bank being on float (i.e. charger not connected to the bus), pilot cell float voltage is determined by measuring pilot cell voltage. The term "full capacity charger" as used in TS 3.8.2.3 is defined as a charger that is capable of supplying an output of 2 300 amperes.

The fuel oil day tank volume limit is a nominal value. Instrument uncertainty need not be applied (reference CR-ANO-2-2003-0821, CA 007).

TS 3.8.1.3 ensures sufficient quantity and quality of stored fuel oil is available to support OPERABILITY of the EDGs. Regulatory Guide 1.137 addresses recommended fuel oil practices as supplemented by ANSI N195-1976. The fuel oil properties assessed by these documents are water and sediment content, specific gravity, kinematic viscosity, and impurity level. SAR Section 9.5.4.1 discusses the mission time of the EDGs based on required stored fuel oil capacity. The stored fuel oil supports operation of the EDGs (TSs 3.8.1.1 and 3.8.1.2) and, therefore, satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). The stored fuel oil is required to be within limits when the associated EDG is required to be OPERABLE.

ARKANSAS - UNIT 2 B 3/4 8-2b Amendment No. 116,198,201,215 Rev.

i ; . . ;"-

Attachment 4 2CAN01 0505 List of Regulatory Commitments

. -_-Attachment 4 to 2CAN01 0505 Page 1 of I List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONT COMPLETION DATE (If COMMITMENT TIME COMPL Required)

ACTION Upon NRC approval of the proposed license X The next ANO-2 SAR amendment, Entergy will revise FSAR amendment after NRC Section 8.3.1.2.4 to remove the statement approval of the license that the Technical Specifications require trip amendment.

setpoints of the primary and backup breakers be checked periodically.