0CAN099208, Application for Amends to Licenses DRP-51 & NPF-6,changing TS to Add LCO & SR for Main Steam Line Radiation Monitors, Per GL 83-37

Application for Amends to Licenses DRP-51 & NPF-6,changing TS to Add LCO & SR for Main Steam Line Radiation Monitors, Per GL 83-37

ML20106C897
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/28/1992
From:	Yelverton J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20106C901	List: 0CAN099208, Application for Amends to Licenses DRP-51 & NPF-6,changing TS to Add LCO & SR for Main Steam Line Radiation Monitors, Per GL 83-37 ML20106C903
References
0CAN099208, CAN99208, GL-83-37, NUDOCS 9210060414
Download: ML20106C897 (7)

Text

o o E ntergy opentions, Inc,

'* " S ES- ENTERGY h r.s ;W /,ii /N1 h.!6m WA H , l Jerry W. Yelverton i ae beat ]

n, . :w Sept ember 28, 1992 OCAN099208 U. S. Nuclear Regulatory Connission Document Cont rol Desk llall Station F1-137 Washington, DC 20$55

Subject:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 & 50-M8 Liernse Nos. OPR-51 & NPF-6 Operational and Surveillance Requirements for Main St eam 1.Ine Radiation Monitors Gentlemen:

At t ached f or your review and appraval are proposed changes to the Arkansas Nuclear boe Units 1 and 2 Technical Specifications (TS) to add limiting conditions for operatlon and surveillance requirements for main steam line radiation monitors in accordance with Generic 1.etter 83-37.

l The proposed changes have been evaluated in accordanco with .

10CI'R$ 0. 91 ( a ) ( 1 ) using criteria in 10CFR$0.92(c) and it has been determined that the changes involve no significant hazards considerations. The bases for these determinations are included in the attached submittal.

Entergy Operations requests that the effective date for these changes be 30 days af ter NHC issuance of the amendment to allow f or dist ribut ion and procedural revisions necessary to implement these changes.

l l Very t ruly yours,

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K'TEf-s5 JWY/GRA/jt

. Attachments i

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'9210060414 920920 PDR ADOCK 0D000313 lh" ' 3 l P PDR .

U. S. NRC Sept ernbe r 28, 1992 OCAN099208 l' age 2 cc: Mr. James L. Milhoan U. S. Nuclear Regulat ory Conunission Region IV

(;11 Ryan Plaza Drive. Suite 400 A r l in gt on , TX 7 f,011 - 8 0 f,4 NRC Senior Resident luspector Arkanuas Nuclear One - ANO-1 h 2 Number 1 Nuclear Plant Road Russellville. AR 72801 Mr. Thomas W. Alexion NRR Project Mariager, Region IV/AND-1 U. S. Nuclear Regulatory Conenission NRR Ma11 St op 13-11-3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Ms. Sherl R. Peterson NRR Project Manager. Region IV/ANO-2 U. S. Nuclear Regulat ory Conanission NRR Mail 5 top 13-11-3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Ms. Greta Dlcus Arkansas Department of ilealt' Division of Radiation Controis and Emergency Management 4815 W. Markham Street.

Litt le Rock, AR 72205 l.

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STATE OF ARKANSAS )

) SS COUNTY OF LOGAN )

Aff. vit I, J. W. Yelverton, being duly sworn, subscribe to and say that I am Vice President, Operations ANO for Entergy Operations, that I have full authority to execute this affidavit that I have read the document numbered OCAN099208 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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j/J. W. Y41verton

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I SUBSCRIBED AND SWORN To before me, a Notary Public in and for the j e i County and State above named, this /f/[dayof dcMer e ,1 4 .

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PROPOSED TECilNICAi, SI'ECIFICATION CilANGr.S l_N_THE MATTER Of AMENDING LICENSE NO. DPR-51 1,1 CENSE NO. N1'F-6 ENTERGY OPERATIONS, INC.

ARKANSAS NUCl> EAR ONE, UNITS 1 AND 2 DOCKET NO. 50-313 DOCKET No. 50-368 h

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!LESCRIPTIOMf_l'ROPOSED Cl!ANGES The proposed changos add limiting conditions for operation and surveillance i requirements for the main steam line radiation monitors in the Arkansns Nuclear One Unit 1 (ANO-1) and Unit 2 (ANO-2) Technical Specifications (TS).

For the ANO-1 TS:

a. Add a new Specification 3.5.1.14 (page 42b) to specify that the main steam linn radiation monitors (MSLRMs) shall be operable;

b. Revisn Tablo 3.5.1-1 (pages 45d2 and 4510 to includo limit ing conditions for operation and an action statement te the MSLRMs; 1

c. Add item 28c in Table 4.1-1 to provido surveillance requirements-for the i HSI.RMs; and -j d- . Add a new specification 6.12.5.m (page 146b) to annote that a Special Report. is rnquired for inoperable MSLRMs.  ;

For the ANO-2 TS:

a. Reviso.Tablo 3.3-6 (pagos 3/4 3-25 and 3/4 3-27 to includo limiting '

conditions for operation and an action statemed for the HSLRMs;

b. Revisc Tablo 4.3-3 (page 3/4 3-27) to include surveillance requirements for '

thn MSLRMs; and

c. Add a new specification 6.9.2.0 (page 6-19a) to denote that- a Special Report is required for inoperabin MSLNHs.

ItACKGROUND NUREG-0737, item II.F.1 Attachment 1, required that noble gas offluent monitors with an extended range be installed to function during accident conditions as well as during normal operating conditions. NUREG-0737 specifically listed '

Pressurized Water Rnactor (PWR) steam safety valvo discharge / atmospheric steam dump valve discharge as an offluent pathway which should be monitored.

Ia response to this requirement, Main Steam Line Radiation Monitors (HShRM) woro installed on Af0-1 and 2.

The HSLRM system is an Zoorlino Modol' RMS Il monitoring system. The detectors are remoto detector assemblies attached between the containment penetration and.

the safety relief valves and provido a signal back.to an indicator for each dntactor in the control room and to the Safety Paramotor Display System-(SPDS). '

The signal from cach indicat.or is also supplied.to a dual pen recorder in the

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control room.- For ANO-1, monitor RE-2681 is strapped to the steam generator (SO} E-24B main steam line and monitor-RE-2682 .is-strapped to the SG E-24A main-steam.line. For ANO-2, monitor 2RE-1007 is strapped to SG 2E-24A main steam line and monitor 2RE-1057 is strapped to SG 2E-248 main steam lino.

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NUREG-0737 also required t. hat TS changes be made to incorporate the noble gas effluent monitors required by item 11.F.1 Attachment 1. Generic Letter 83-37 was issued November ), 1983 to specify the TS changes that the NRC would find acceptable for implementing the requirements of NUREG-0737. Generic Letter 83-37 included TS changes for the noble gas effluent monitors. By Sys Evaluation,Noble Gas Monitor & Iodine Particulate Sampling,Per NUREG-0737 Items|letter dated March 16, 1984]] (OCANO38401) ANO responded to Generic Letter 83-37. The response to Generic Letter 83-37 referred to the submittal dated September 30, 1983 (OCAN098310) which proposed the radiological effluent TS (RETS) as satisfying the requirement to submit the necessary TS changes for the nobio gas effluent moultors. The RETS change included the noble gas effluent. pathways described in NUREG-0737 item 11.F.1 Attachment 1 except the pWR steam safety valve discharge / atmospheric steam dump valve discharge. The MSLRMs which monitor this pathway were inadvertently omitted from the RETS submittal.

DISCUSSibN Generic Lett er 83-37 provided sample TS pages for ircorporating Limiting conditions for Operation and Surveillance Requirements for the' noble gas effluent monitors. The proposed TS changes are consistent with the generic letter except for the specification of a setpoint for the MSLRMs and th*3 measurement range has been converted to mR/hr to be consistent with the I

indication scale. No setpoint is specified for the AND-1 TS and "not applicable" is specified for the ANO-2 TS based on the following considerations:

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1) No regulatory requirement could be found t. hat requires a-setpoint be specified in the TS for these monitors.

2) The latest draft of the Revised Standard TS does not include the radiation monitor table. Instead, these monitors would be included in the post accident monitor table which does not include a column for setpoints.

3) The Waterford 3 TS have the main steam'line radiation monitors in.the radiation monitoring table with "not applicable" specified for the setpoint. -

4) The ANO-2-radiationLmonitoring table specifies "not applicable" for the Containment High Range Area Radiation Monitors which were added to the radiation monitor table as A result of Generic Letter 83-37 and was approve the NRC in Amendment 63 to the-ANO-2 TS. The Containment High Range a. che Main Steam Line Radiation Monitors are both post accident-type monitors which the' operators' can use for information .to make post accident decisions. -Instruments which perform only a post accident monitoring function have typically not had alarm / trip setpoints specified in the TS.

Consistent with Generic Letter 83-37, the proposed changes require =the MSLRMs to be operable whenever-the reactor is above the cold shutdown condition. In L . case of failure of the MSLRMs an alternate preplanned method of monitoring this effluent pathway-is required to be established within 72 hrurs. The alternate L method could, for example, involve obtaining a sample of main' steam line condensate and analyzing the sample by gamma spectroscopy, relying on the l

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i installed N-16 monitors, or temporarily positioning a local radiation survey lustrument on the main steam line. The inopereSle monitor must. be restored to I operable status within 7 days or a special report must be submitted within 14 .

days describing the inoperable condition, the actions taken to correct the condition, and the plans and schedule for restoring the system to an operable status.

t DETERMINATION OF SIGNIFICANT HAZARDS ,

An evaluatien uf the proposed change has been performed in accordance with ,

10CFR50.91(a)(1) tegarding no significant hazards considerations using the '

standards in 10CFR50.92(c). A discussion of these standards as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant Increase in the Probability or consequences of an Accident Previously Evaluated.

The Main Steam Line Radiation Monitors (MSLRM) do not_ provide information that is required to safely shutdown the plant. The monitors provide release information for evaluating offsite emergency action when venting through the steam safety and atmospheric dump valve paths. Also, with this change there are no modifications to the configuration or the operation of the plc.nt. This change only adds operability and surveillance requirements for these monitors.

• Therefore, this change does not involve a significant increase in the probability or consequences of any accident previously evaluated.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.

f' The MSLRMs are used to provide passive monitoring of radiation icvels during and following an accident in which a primary to secondary system leak has occurred. The accident conditions for which the monitors would provide useful information have previously been analyzed. Therefore, this change does not 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 MSLRMs are not required to safely shutdown the plant. The proposed change imposes additional limitations, restrictions, or controls not presently in the TS. Therefore, this change does not involve-a significant reduction in the margin of safety.

The Commission has provided guidance, in 51FR7750 (3/6/86;,_ concerning the '

application of 'hese 10CFR50.92 standards by providing-examples of amendtnents which are likely to involve no significant hazards corsideratioas. The proposed amendment most closely matches exampia B(li) "A chan@ that--

constitutes an_ additional limitation, restriction, or control not_ presently ,

included in the technical specifications, eq., a uore stringent surveillance requirement."

Therefore, based on the above and the previous dDetnion of the amendment request, Entergy Operations-has determined,that tSo requested change does not-involve a significant hazards consideration. ,

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