2CAN049902, Application for Amend to License NPF-6,adding TS 3.0.6 & Associated Bases to ANO-2 Ts.Proposed Specification Is Identical to Specification 3.0.5 of NUREG-1432, Improved STS CE Plants, Rev 1
| ML20205P685 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/09/1999 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20205P689 | List: |
| References | |
| RTR-NUREG-1432 2CAN049902, 2CAN49902, NUDOCS 9904200290 | |
| Download: ML20205P685 (9) | |
Text
.
Entsrgy operztions, Inc.
- Enteray
=-
Tei yM FM ep C. Randy Hutchinson ww Q 044 tis !N)
April 9,1999 2CAN049902 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station OPI-17 Washington, DC 20555
Subject:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Proposed Technical Specification Change Request Revising Section 3.0 Requirements Gentlemen:
Attached for your review and approval is a proposed Technical Specification change that adds
//
Specification 3.0.6 and its associated bases to the Arkansas Nuclear One-Unit-2 (ANO-2)
/
Technical Specifications. This change will allow equipment removed from service or declared inoperable to comply with actions to be returned to service under administrative controls solely to perform testing required to demonstrate its operability or the operability of other equipment. This proposed specification is identical to Specification 3.0.5 of NUREG 1432,
)
" Improved Standard Technical Specifications Combustion Engineering Plants," Revision 1. A complete discussion of this change is included in the attachment to this submittal.
The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations are included in the attached submittal.
Although this request is neither exigent nor emergency, your prompt review is requested due to an existing condition relative to the ANO-2 Excore Nuclear Instmmentation System. The "D" excore instrument channel is currently operable; however, trending data indicates that it is degrading and may ultimately be declared inoperable. If the channel does fail, the ANO-2 TS allow continued operation with the failed channel in the trip or bypass condition until the next cold shutdown. The proposed amendment will allow removing the trips or bypasses from the affected channel during surveillance testing to facilitate ve-ifying operability of the related protective channels. This capability will reduce the potential for an inadvertent plant trip due to a spurious signal during testing. Based on the schedule for RPS Matrix Logic surveillance testing, this amendment is requested by June 15,1999. To facilitate prompt implementation, Entergy Operations requests that the effective date for this change be upon issuance of the amendment.
m
~
9904200290 990409 PDR ADOCK 05000368-P PDR
U. S. NRC I
April 9,1999 2CAN049902 Page 2 l
Very truly yo rs, jj A
~
y CRH/rhs Attachments i
To the best of my knowledge and belief, the statements contained in this submittal are i
true.
SUBSCRIBED AND SWORN TO before me, a Notary Public in and for h
County and the State of Arkansas, this M day of O B
,1999.
j l
7:::::::::::::::::::::::_
l h
" OFFICIAL SEAL" d
Andrea Pierce A.^^
= " ' - - "
l Notary Public, State of Arkansas C Notary P' blic County of Pope
)
u My Commission Empires / A/rf/.2do 7
@grnnug ng2nyng cc:
Mr. Ellis W. Merschoff 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. Box 310 London, AR 72847 Mr. Chris Nolan NRR Project Manager Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 RocHile Pike Rockville, MD 20852 Mr. David D. Snellings Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205
9 S
ATTACHMENT 2CAN049902 PROPOSED TECHNICAL SPECIFICATION AND RESPECTIVE SAFETY ANALYSES IN TIE MATTER OF A. MENDING LJCENSE NO. NPF-6 ENTERGY OPERATIONS. INC.
ARKANS AS NUCLEAR ONE. UNIT TWO DOCKET NO. 50-368 i
1 I
I 1
Attachment to 2CAN049902 Page1of5 DESCRIPTION OF PROPOSED CHANGES i
The proposed change will modify the Arkansas Nuclear One Unit-2 (ANO-2) Technical
)
Specifications (TS) by adding TS 3.0.6 and its associated bases. This new specification 1
provides an exception to TS 3.0.2 and allows equipment removed from service or declared
)
inoperable to comply with actions to be returned to service under administrative controls i
solely to perform testing required to demonstrate its operability or the operability of other I
equipment. This proposed change is identical to Limiting Condition for Operation 3.0.5 of the l
Combustion Engineering Improved Standard Technical Specifications (STS), NUREG 1432.
l TS 3.0.2 will also be modified to reflect that TS 3.0.6 is an exception to TS 3.0.2.
j
)
BACKGROUND i
The ANO-2 excore nuclear instrumentation system includes four safety channels. Each safety j
channel utilizes a fission chamber assembly made up of three detectors which are used to measure the flux in the upper, middle, and lower regions of the core independently. The j
safety channels have two ranges: wide range log power (2x10 to 200%) and wide range j
linear power (0 to 200%).
i Each detector feeds a linear amplifier which provides input to the Reactor Protective System (RPS) Core Protection Calculator (CPC) trips for Local Power Density (LPD) - high and
]
Departure from Nucleate Boiling Ratio (DNBR) - low. Outputs of the three linear amplifiers (per channel) are also provided to a summer which averages the signals and provides input to the linear power level - high trip. The center detector also inputs to the log power circuitry which inputs to the logarithmic power - high trip.
j ANO-2 TS Table 3.5-1 requires that three of four channels of the linear power level - high, LPD - high, DNBR-low, and CPC functions be operable in Modes 1 and 2, and that three of
]
four channcis of the logarithmic power level - high function be operable in Mode 2 and in Modes 3, 4, and 5 when the protective sysicm trip breakers are closed, and the Control Element Assembly (CEA) drive system is capable of CEA movement.
Action 2 of Table 3.3-1 states, "With the number of channels OPERABLE one less than the i
Total Number of Channels, operation in the applicable MODES may continue provided the i
inoperable channel is placed in the bypassed or tripped condition within I hour. If the inoperable channel is bypassed for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the desirability of maintaining this channel in the bypassed condition shall be reviewed at the next regularly scheduled PSC meeting in accordance with the QA Manual Operations. The channel shall be returned to OPERABLE status prior to startup following the next COLD SHUTDOWN."
The normal RPS trip configuration is such that two of four channels must actuate to initiate the protective function. With one channel in the bypass condition, the trip logic becomes a two of three logic configuration.
As previously stated, The "D" excore instmment channel is currently operable, but slowly degrading, and may ultimately be declared inoperable. If the channel does fail, the TS allow
Attachment to 2CAN049902 Page 2 of 5 continued operation with the failed channel in the trip or bypass condition until the next cold shutdown.
The ANO-2 TS do not contain specific provisions for returning an inoperable channel to service under administrative controls to facilitate testing.
Since the RPS test circuitry configuration allows only one channel of any protective function to be placed in the bypass condition, a failed channel must be placed in the tripped condition so that another channel can be placed in bypass to perform surveillance testing. With the failed channel in the trip condition and another channel in bypass for testing, the RPS is reduced to a one out of two actuation configuration, which increases the likelihood of an inadvertent plant trip.
l The addition of specification 3.0.6 will allow an inop:rable channel to be returned to service 1
(not in bypass or trip) under administrative controls to facilitate testing of the other channels without increasing the likelihood of an inadvertent plant trip. This configuration would place the RPS actuation logic in a two out of two configuration making the system temporarily single failure vulnerable. However, the likelihood of an event requiring RPS actuation during the short time intervals in which the system would be in this condition was evaluated as being below the threshold for risk consideration. Additionally, the establishment of administrative controls provide further assurance that the protective function would occur, if required.
A similar TS change was approved for Waterford Steam Electric Station, Unit 3 by issuance of Amendment No.101 to the Facility Operating License, dated March 1,1995.
DISCUSSION OF CHANGE The addition of Specification 3.0.6 estab"shes the allowance for restoring equipment to service, under administrative controls, whc i it has been removed from service or declared inoperable to comply with actions. The sole purpose of this Specification is to provide an exception to Specification 3.0.2 allowing the performance of Surveillance Requirements to demonstrate:
- a. The operability of the equipment being returned to service; or I
- b. The operability of other equipment.
j An example of demonstrating the operability of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with required actions i
and must be reopened to perform the surveillance requirements.
Another example of demonstrating the operability of equipment being returned to service is the testing of an inoperable Service Water (SW) pump on an operable SW loop. In order to prove operability of a SW pump following maintenance, it is necessary to run the pump connected to a SW loop j
An example of demonstrating the operability of other equipment is taking an inoperable channel of a trip system out of the tripped condition to prevent an inadvertent trip from
(
occurring during the performance of a surveillance requirement on another channel in the
Attachment to 2CAN049902 Page 3 of 5 same trip system. A similar example of demonstrating the operability of other equipment is taking an inoperable channel of a trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of a surveillance requirement on another channel in the same trip system.
The addition of specification 3.0.6 will allow an inoperable channel of RPS to be returned to service (not in bypass or trip) under administrative controls to facilitate testing of the other channels without increasing the likelihood of an inadvertent plant trip. This configuration would place the RPS actuation logic in a two out of two configuration. Although this configuration is not single failure proof, the safety function would remain available.
The probability of the occurrence of an event requiring RPS actuation during the short time intervals in which the system would be in this condition is very low. Additionally, the establishment of administrative controls will ensure the time the equipment is returnad to service in conflict with the requirements of the actions is limited to the time absolutely necessary to perform the necessary surveillance requirements. This Specification does not provide time to perform any other preventive or corrective maintenance.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Entergy Operations, Inc. is proposing that the ANO-2 Operating License be amended to allow equipment removed from service or declared inoperable to comply with actions to be returned to service under administrative control solely to perform testing required to demonstrate its operability or the operability of other equipment.
1 An evaluation of the proposed change has been performed in accordance with j
10CFR50.91(a)(1) regarding no significant hazards considerations using the standards in 10CFR50.92(c). A discussion of these standards as they relate to this amendment request follows:
l Criterion 1 -
Does Not Involve a Significant Increase in the Probability or Consequences of an Accider.t Previously Evaluated.
The proposed change will allow an orderly return to service ofinoperable equipment.
This change does not alter the functional characteristics of any plant component and does not allow any new modes of operation of any component.
The accident mitigation features of the plant are not affected by the proposed amendment request.
Therefore, this proposed amendment will not result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site. No modifications have been made to the plant due to this amendment request.
Specification 3.0.6 will permit equipment removed from service to comply with required actions to be returned to service under administrative controls to verify the operability of the equipment being returned to service or of related equipment.
Although returning inoperable equipment to service for testing may temporarily compromise single failure criteria, administrative controls will ensure the time involved will be limited to only that required to demonstrate component or system operability.
This new specification provides an acceptable method of demonstrating the operability
Attachment to 2CAN049902 Page 4 of 5 of TS equipment before it is returned to service and allows verifying other TS equipment is operable.
Therefore, this change does nut involve a significant increase in the probability or consequences of any accident previcusly evaluated.
Criterion 2 -
Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.
No modifications were made to the plant due to this amendment request. The proposed change does not alter the functional characteristics of any plant component and does not allow any new modes of operation of any component. This proposed amendment will facilita.e the testing of equipment in its design configuration to demonstrate operability. This testing will be limited to the time absolutely necessary to perform the test.
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 addition of specification 3.0.6 will allow an inoperable channel of RPS to be returned to service (not in bypass or trip) to facilitate testing of the other channels, thereby decreasing the likelihood of an inadvertent plant trip. This configuration would place the RPS actuation logic in a two out of two configuration. Although this configuration is not single failure proof, the safety function would remain available.
The probability of the occurrence of an event requiring RPS actuation during the short time intervals in which the system would be in this condition is very low. Additionally, the establishment of administrative controls will ensure the time the equipment is returned to service in conflict with the requirements of the actions is limited to the time absolutely necessary to perform the necessary surveillance requirements. This Specification does not provide time to perform any other preventive or corrective maintenance.
Therefore, based upon the reasoning presented above and the previous discussion of the amendment request, Entergy Operations has determined that the requested change does aqt involve a significant hazards consideration.
ENVIRONMENTAL IMPACT EVALUATION 10 CFR 51.22(c) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a
Attachment to 2CAN049902 Page 5 of 5 significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site, or (3) result in a significant increase in individual or cumulative occupational radiation exposure. Entergy Operations, Inc. has reviewed this license amendment and has determined that it meets the eligibility criteria for categorical exclusic. set forth in 10CFR51.22(c)(9).
Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the proposed license amendment. The basis for this determination is as follows:
1.
The proposed license amendment does not involve a significant hazards consideration as described previously in the evaluation.
2.
As discussed in the significant hazards evaluation, this change does not result in a significant change or significant increase in the radiological doses for any Design Basis Accident. The proposed license amendment does not result in a significant change in the types or a significant increase in the amounts of any effluents that may be released off-site.
3.
The proposed license amendment does not result in a significant increase to the individual or cumulative occupational radiation exposure because this change does not alter the functional characteristics of any plant component and does not allow any new modes of operation of any component.. The accident mitigation features of the plant are not affected by this change.
4 i
PROPOSED TECHNICAL SPECIFICATION CHANGES