ML20043B693

Application for Amend to License DPR-51,revising Tech Spec 3.1.2.10 Re HPI During Cold Shutdown to Enhance Response to Loss of DHR & Ensure Availability of at Least One HPI Pump, Per Generic Ltr 88-17

ML20043B693
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/22/1990
From:	Carns N ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20043B694	List: ML20043B693 ML20043B701
References
1CAN059008, 1CAN59008, GL-88-17, NUDOCS 9005310146
Download: ML20043B693 (7)

Text

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t ICAN059008 i

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'O. S.. Nuclear'Regulaiory Commission i Docume'nt Control Desk-Mail Station P1-137 .

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Subject:

Arkansas Nuclear One - Unit 1 i f Docket No. 50-313 .

License No. DPR-51 Technical-Specification Change _ Request High Pressure Injection During Cold Shutdown  ;

s' " Gentlemen':

e Arkansas Power &-Light (AP&L) has identified a change to the ANO-1 Technical:

-Specification (TS) 3.1 J 10 which would; enhance our response to a loss of, I*

decay heat removal event. Adequatt. sources of inventory' addition to the reactor coolant system. including the availability of at least one high pressure: injection pump is delineated as a' recommendation of Generic Letter  !

No. 88-17,sLoss'of Decay Heat Removal. The. current TS. requires that all  !

..four ofJthe High Pressure-Injection (HPI) motor operated. valves be' closed i T .and~ disabled when thetRCS is less than 280 F with certain exceptions. AP&L l'

• _ proposes to' add the use of high. pressure injection for emergency makeup to

~that. list of: exceptions byiallowing HPI motor operated. valves to be available ,

s "when required for emergency makeup.

l' In accordance with 10CFR50.91(a)(1), and using the criteria in 10CFR50.92(c),

AP&L'has: determined-that this change involves no'significant hazards Lconsideration. Our basis'for this determination and copies of the proposed

. change'are attached for your review. The circumstances of this amendment 2 L request are'.neither exigent or emergency, however, prompt implementation of

.this proposed. change would' enhance our response to a loss of decay heat removal. event.

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[- 9005310146 900522 "% OC/

. PDR ADOCK 05000313

-P PDC An Enwov company gJ m, _a

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._ May - 22, .1990

f. y AP&L' requests that. the effective date for this change be when issued by the -

' NRC.=

, Sincerely, 7 ( f-h NSC/1w .

Attachments lcc: Mr. Robert Martin-U.' S. Nuclear Regulatory Commission Region.IV-

'611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

. NRC Senior' Resident Inspector Arkansas Nuclear One - ANO-1 & 2 Number 1 . Nuclear Plant Road Russellville,AR72801 Mr. C. Craig Harbuck .

NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory. Commission' NRR Mail Stop:13-D-18 One White Flint North' 11555 Rockville Pike Rockville, Maryland-20852 1

-Mr.:Chester Poslusny- q NRR Project Manager, Region IV/ANO-2 :J; U. S.ENuclear Regulatory Commission NRR-Mail Stop 13-D-18 One White Flint North 4' 11555 Rockville Pika -!

Rockville, Maryland 20852 1 Ms. Greta Dicus, Director if Division of~ Radiation Control

'. and Emergency Management -l b Arkansas Department of Health  !

4815 West Markham' Street i Little Rock, AR 72201 :1 1

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PROPOSED TECHNICAL SPECIFICATION CHANGE IN THE MATTER 0F AMENDING LICENSE N0. DPR-51

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ARKANSAS POWER & LIGHT COMPANY ARKANSAS-NUCLEAR ONE, UNIT 1 m

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DOCKET NO. 50-313 1

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?- STATE OF ARKANSAS

, SS y- COUNTY OF POPE I, N. S. Carns, being duly sworn, subscribe to and say that I am Vice President, Nuclear for Arkansas Power & Light Company;.that I have full authority to execute this oath; that I have read the document numbered ICAN059008 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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N. S. Carns i

SUBSCRIBED AND SWORN T0 efore me, a Notary Public in and for the-County and State above named, this da day of Wm('

E 1990.

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's PROPOSED CHANGE-It is proposed that Technical Specification 3.1.2.10 be changed-to add

" emergency RCS makeup" to the list of exceptions to disablin motor control circuits for the High Pressure Injection (HPI)gmotor the opening operated 1

- valves as specified on page 18a of the AN0-1 Technical Specifications (TS). I in No change to the basis for this specification is required. j L .!

[ -BACKGROUND Generic letter No. 88-17, Loss of Decay Heat Removal, recommended as a

) . programmed enhancement (Item 5) that Technical. Specifications which restrict

[ or limit the safety benefit of the actions identified in the generic letter g be identified and appropriate changes be submitted. Additionally,.the

. ceneric letter recommends that at least two means of adding inventory to the gl 7 Reactor Coolant System that are in addition to pumps that are a part of the normal DHR system be

available or operable. These should include at least one high pressure injection pump. Requiring the High Pressure injection motor operated valves to be closed with their opening control circuits for j r the motor operators dicabled (TS 3.1.2.10) precludes the motor operated i valves for the-HPI pumps from being used for emergency makeup without i violation of the Technical Specification.- Exceptions to this TS are  !

, currently allowed; therefore, AP&L proposed to add the use of HPI valves for j

" emergency RCS makeup" during decay heat removal operation to the list of i exceptions. Procedures currently exist for the use of the HPI pump as an {

emergency-source of makeup with specific instructions to prevent j overpressurization during emergency RCS makeup by instructing the operator j

-to throttle HPI to prevent exceeding LTOP limits. l i

DISCUSSION l

'The current Technical Specification 3.1.2.10 requires that when the reactor coolant temperature is less than 280 F, the four High Pressure Injection d

.(HPI) motor operated valves shall be closed with their opening control f circuits for the-motor operators disabled. The specification allows q exceptions for ASME Section XI testing, fill and vent of the reactor coolant ,

system, and to allow maintenance of the valves. This change would allow valve (s) to be operable during decay heat removal operation for emergency RCS makeup. The valve (s) will be maintained closed and disabled unless needed. Procedural controls exist to throttle the valve (s) under circumstances consistent with the available vent path such that an overpressurization event does not occur.

i Basis for Proposed No Significant Hazards Consideration Determination In accordance with 10CFR50.92, AP&L has evaluated whether the proposed change involves a significant safety hazards consideration. AP&L has concluded that the proposed change to Specification 3.1.2.10 does not involve a significant hazards consideration because the operation of Arkansas Nuclear One, Unit 1 in accordance with this change would not: .

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~(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The change allows use 'of the HPI system to mitigate a loss of Decay. y Heat Removal.' event without violating Technical Specifications. The Technical Specification currently: require the HPI block valves to be closed during low pressure operatlon to prevent a low temperature overpressurization event. The proposed change would not significantly increase the-probability of a low temperature overpressurization accident because of the availability of the Electromatic Relief Valve,-

which is reset for a value associated with low pressure operations, and procedural controls which require the throttling of HPI. flow consistent with the available vent path. Additionally, once cooled down a pressurizer manway is removed to provide-a vent path to preclude RCS pressurization due to a loss of decay heat removal event.

This change would not adversely affect the consequences of accidents which have previously been evaluated. The proposed change makes available, without violation of Technical Specification, the HPI system as a source of makeup:for a loss of inventory condition while in Decay

. Heat Removal Operations, and therefore increases the ability to mitigate the consequences of a loss of Decay Heat Removal event. Thic change to the Technical Specification will not alter the plant capabilities'or protective features, but will remove the operator's_

reservations about using the HPI system to mitigate a loss of Decay Heat Removal event.

'(2) Create the possibility of a new or different kind of accident from any previously evaluated.

No new possibility-for an accident is introduced by allowing the use of the HPI system as a source of inventory for boil off due to a loss of decay heat removal. The proposed amendment will not change the overall design and system function of the HPI system. This change will allow  ;

the use of the HPI pumps and valve (s) as a sources of water for inventory replenishment in a loss of Decay Heat Removal event. The HPI valve availability is currently allowed as an inventory source during fill'and vent of the RCS, which is a normal evolution._ Low Temperature Overpressurization was evaluated and a Safety Evaluation Report issued in association with Amendment Number 95 to the ANO-1 Facility Operating License. The procedural controls. in place ensure that overpressurization does not occur by using the valve only after all other sources of inventory addition have been exhausted, and, then, with operator attention focused on LTOP considerations.

(3) Involve a significant reduction in the margin of safety.

The proposed change allows use of the HPI pump and associated valve (s) {

as a source of inventory addition to the RCS in a Loss of Decay Heat Removal event. This change does not involve a significant reduction in the margin of safety and in fact will increase the margin of safety by adding an additional inventory source as recomended in Generic Letter No. 88-17. The HPI valve availability is currently allowed for RCS fill and vent and other evolutions. The procedural controls ensure

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that overpressurization does not occur by using the valve only after all other sources of inventory -addition have been exhausted, and, then, with operator attention focused on LTOP considerations.

The NRC has provided guidance concerning the application of these standards

- by.providing examples of changes: involving no significant hazards considerations. The proposed amendment most closely matches example (vii):

"A change to c:nform a license to changes in the regulations where_ the a' license changs results in very minor changes to facility operations clearly in keeping with the regulations."

The proposed change enhances our response to Generic Letter.88-17 by providing, the HPl system.as an-available source of inventory addition, while incurring little increase in the probabi.lity of an overpressurization event,

, ,Therefore, based on the evaluation discussed above, AP&L has concluded that the-proposed change does not involve a significant hazards consideration.

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