2CAN049604, Responds to NRC Questions Re Containment Air Lock TS Change Request

Responds to NRC Questions Re Containment Air Lock TS Change Request

ML20108A969
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/25/1996
From:	ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20108A970	List: 2CAN049604, Responds to NRC Questions Re Containment Air Lock TS Change Request ML20108A972
References
RTR-NUREG-1432 2CAN049604, 2CAN49604, NUDOCS 9605030093
Download: ML20108A969 (5)

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T @GY Entergy operations, Inc.

'4483 n 333 RecMe. AR 72301 Td 501858-5000 i

I April 25,1996 2CAN049604 U. S. Nuclear Regulatory Commission Document Control Desk

• Mail Station PI-137 Washington, DC 20555

Subject:

Arkansas Nuclear One - Unit 2 -

Docket No. 50-368 l 4

License No. NPF-6 l Response to NRC Questions Regarding Containment Air Lock Technical  !

Specification Change Request  :

Gentlemen. 7 4

I By letter dated April 4,1995 (2CAN049511), Entergy Operations requested changes to the

Arkansas Nuclear One-Unit 2 (ANO-2) Technical Specifications (TS) to incorporate the

, provisions of NUREG-1432 specification 3.6.2 into our current TS 3.6.1.3. In your Request ,

For Additional Information (ANO-2 TAC M92068) dated November 15,1995, you requested specific information and consideration of a revision to our original submittal. Attached is our '

( response to your request and revised pages of the original ANO-2 TS change request. The evaluation related to the determination of significant hazards provided in our original

} submittal, 2CAN049511, remains unaffected by the change.

Should there be any additional questions regarding this information, please contact me.

Very a oly yours,

[ .

, A DCM/lgm

. Attachments

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l I ADOCK 05000368 k l PDR l

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U. S. NRC April 25,1996 2CAN049604 Page 2 l cc: Mr. Leonard J. Callan Regional Administrator  :

U. S. Nuclear Regulatory Commission Region IV l

611 Ryan Plaza Drive, Suite 400 l Arlington, TX 76011-8064 l

NRC Senior Resident Inspector l Arkansas Nuclear One '

P.O. Box 310 London, AR 72847 1

Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2  :

U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Arkansas Department of Health Division ofRadiation Control '

and Emergency Management 4815 West Markham Street i Little Rock, AR 72205 i

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Attachment to l 2CAN049604  !

.Page l'of 2 Response to NRC Questions on Containment Airlock Technical Specification Change Request i

1. Please describe the administrative controls that would be implemented with both air locks inoperable for entry and exit (proposed note 2 to action 3.6.1.3.a.). Include the proposed procedure,if available.

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The administrative controls that would be implemented with both air locks inoperable

would be the same as with one air lock inoperable. An operator will be stationed locally,

at each air lock, to maintain the operable door closed, except for containment entry and

exit. The seven day time clock will be tracked by our normal tracking tools, such as;

status board entries, station log entries and our shift turnover process. Revisions to procedures are not typically initiated until the requested amendment is approved. . Note a that the term " operator", in this case, does not necessarily mean a member of the permanent plant operating staff, but rather a capable individual who has been trained for

. the specific task.

2. Please confirm that the proposed leakage rate of TS 4.6.1.3.1.a. would not result in a total containment leakage above the existing analyses for all evaluated accidents.

TS 4.6.1.3.1.a is intended to detect degradation of the airlock door seals following the

! opening and closing of the airlock doors. The proposed air lock door seal leakage rate

limit is 1% of the total containment leakage assumed in accident analysis. TS 4.6.1.3.1.b requires the performance of an overall airlock leakage test. This test has a limit of 5% of the total containment leakage assumed in the accident analysis. This test is a Type B test and the results are added to the total of all Type B and C tests. The total of the Type B i and C tests must be less than 60% of the total allowed containment leakage. This ensures that the leakage through the airlock will not exceed the leakage assumed in the existing analyses for all evaluated accidents.

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3. Please describe the controls that would be implemented for entry and exit with an inoperable interlock. Include the proposed procedure,if available. Please confirm that the dedicated individual described in note 4 to TS action 3.6.1.3.b. would be located in the immediate vicinity of the air lock (the submittal states "at the air Ictk") and would have no other duties than to ensure that at least one air lock door is closed at all times.

- The intended administrative controls for compliance with this specification include stationing an operator in the immediate vicinity of the air lock, with no concurrent duties, i to ensure that one door remains closed at all times. Note that the term " operator", in this l case, does not necessarily mean a member of the permanent plant operating staff, but rather a capable individual who has been trained for the specific task.

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Attachment to 2CAN049604

.Page 2'of 2

4. The existing ANO-2 TS 3.6.1.3.a.4. specifies that the provisions of TS 3.0.4 are not applicable. Standard TS 3.0.4 states that "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time." The proposed change relocates this statement to 3.6.1.3.d. thus making it applicable to all actions including those that are not indefinite. It appears that this proposed change is not appropriate. Proposed note 2 to TS 3.6.1.3.a. only allows containment entry for seven days with both air locks inoperable due to inoperable air lock doors. Proposed TS 3.6.1.3.c. allows 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to hot standby with one or more air locks inoperable for reasons other than an inoperable door or interlock.

Please revise the submittal to correct this item or provide strong justification for the proposed deviation from the STS.

Attached is the revised Technical Specification page with the 3.0.4 exemption removed.

When the recommendations of Generic Letter 87-09 were incorporated into the ANO-2 TS, it was determined that an exception to 3.0.4 was necessary to preserve the capability to enter MODE 4 with an inoperable airlock door. When the most recent proposed change was written, ANO incorrectly relocated the 3.0.4 exception to 3.6.1.3.d. Upon further review, ANO has determined that action statement 3.6.1.3.a.2 would permit continued operation in the MODE of Applicability for an unlimited period of time; therefore, an exception to 3.0.4 is not necessary. This position is consistent with the requirements of the Improved Standard TS.

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PROPOSED TECHNICAL SPECIFICATION CHANGES 5

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CONTAENMENT SYSTEMS

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• CONTAINMENT AIR LOCKS LIMITING CONDITION FOR OPERATION 3.6.1.3 Each containment air lock sh'all be OPERABLE. l APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one containment air lock door inoperable in one or more containment air locks i ,2,

1. Verify that at least the OPERABLE air lock door is closed in the affected air lock within one hour and either restore the inoperable air lock door to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or lock the '

OPERABLE air lock door closed'.

2. Operation may then continue provided that the OPERABLE air lock door is verified to be locked closed at least once per 31 days.

3. Otherwise, be in at least HOT STANDBY within the next six hours and ,

in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With the containment air lock interlock inoperable in one or more I

containment air locks l:

1. Verify that at least one OPERABLE air lock door is closed in the affected air lock within one hour and restore the inoperable air lock interlock to OPERABLE Jtatus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or lock an OPERABLE air lock door closed *. ,

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2. Operation may then continue provided that the OPERABLE air lock door is verified to be locked closed at least once per 31 days.

3. Otherwise, be in at least HOT STANDBY within the next six hours and '

in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c. With one or more air locks inoperable for reasons other than those 4 addressed in ACTION a. or b.: ,

1. Immediately initiate action to evaluate overall containment leakage per LCO 3.6.1.2.

2. Verify that at least one door in the affected ait lock is closed t within one hour and restore the affected air lock to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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! 3. Otherwise, be in at least HOT STANDBY within the next six hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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' Separate ACTION entry is allowed for each air lock.

2 With both air locks inoperable, entry and exit is permissible for seven days under administrative controls.

' Entry and exit is permissible to perform repairs on the affected air lock components.

' ' Entry and exit is permissible under the control of a dedicated individual.

ARKANSAS - UNIT 2 3/4 6-4 Amendment No.

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• MARKUP OF CURRENT ANO-2 TECHNICAL SPECIFICATIONS (FOR INFO ONLY) l l

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