RBG-46754, Revision to License Amendment Request, Application for Technical Specification (TS) Change Regarding Ventilation Filter Testing Program (Vftp), TS 5.5.7, Control Room Fresh Air System (Crfas) Heater Wattage

Revision to License Amendment Request, Application for Technical Specification (TS) Change Regarding Ventilation Filter Testing Program (Vftp), TS 5.5.7, Control Room Fresh Air System (Crfas) Heater Wattage

ML072990062
Person / Time
Site:	River Bend
Issue date:	10/24/2007
From:	Olson E Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBF1-07-0195, RBG-46754
Download: ML072990062 (7)

Text

Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N Entergy St. Francisville, LA 70775 Tel 225-381-4374 Eric W. Olson Vice President, Operations (Acting)

River Bend Station October 24, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Revision to License Amendment Request Application for Technical Specification (TS) Change Regarding Ventilation Filter Testing Program (VFTP), TS 5.5.7, Control Room Fresh Air System (CRFAS) Heater Wattage River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47

REFERENCE:

Letter RBG-46669, "Application for Technical Specification (TS) Change Regarding Ventilation Filter Testing Program (VFTP), TS 5.5.7, Control Room Fresh Air System (CRFAS) Heater Wattage Request from Joseph E. Venable of Entergy to USNRC dated March 28, 2007 (ADAMS Accession No. ML4961)

RBG-46754 RBF1-07-0195

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) is providing the attached administrative revisions to several pages of a previously submitted amendment for River Bend Station, Unit 1 (RBS).

Entergy had requested a modification of the River Bend Technical Specifications (TS) to revise the Control Room Fresh Air System (CRFAS) heater wattage (kW) requirement shown in Technical Specification 5.5.7 Ventilation Filter Testing Program, subsection TS 5.5.7.e.

The revised pages update the titles of the referenced Regulatory Guide and ASME standard in the original submittal. The revisions do not affect any of the technical information in the request. The revisions do not affect the original no significant hazards consideration.

LA-,l

RBG-46754 Page 2 of 2 The proposed change does not include any new commitments.

If you have any questions or require additional information, please contact Bill Brice at 601-437-5076.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 24, 2007.

Sincerely, Eric W. Olson Vice President, Operations (Acting)

River Bend Station, Unit 1 EWOIWBB

Attachment:

Revised Pages cc: Mr. Elmo E. Collins, Jr.

U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U.S. Nuclear Regulatory Commission Attn: Mr. Bhalchandra K. Vaidya MS 0-7D1 Washington, DC 20555-0001 Louisiana Department of Environmental Quality Office of Environmental Compliance Attn: Mr. Jeff Meyers Surveillance Division P. 0. Box 4312 Baton Rouge, LA 70821-4312

Attachment I RBG-46754 Revised Pages for Entergy letter RBG-46669 to RBG-46669 Page 1 of 4

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-47 for River Bend Station, Unit 1 (RBS).

The proposed change will revise the Operating License to revise the Control Room Fresh Air System (CRFAS) heater wattage (kW) testing requirement shown in Technical Specification 5.5.7 Ventilation Filter Testing Program, subsection TS 5.5.7.e.

2.0 PROPOSED CHANGE

Technical Specification 5.5.7.e., Ventilation Filter Testing Program, specifies the required power (in kW) for the Control Room ventilation electric heaters (HVC*FLT3AH/3BH) to decrease relative humidity of the air to less than 70 percent as required for proper operation of the charcoal absorber components when tested in accordance with ASME N510-1989 "Testing Of Nuclear Air Treatment Systems." Entergy proposes to revise the CRFAS heater wattage testing requirement from 23 +/- 2.3 kW, to a new value of > 15 kW.

There are no associated Technical Specification Bases changes.

3.0 BACKGROUND

Removal of radioiodines from the main Control Room ventilation outside air supply during a Design Bases Accident (DBA) is accomplished through use of charcoal filter trains. To comply with the Control Room radiation protection requirements of 10 CFR 50.67, "Accident Source Term" two 100-percent capacity redundant charcoal filter trains are provided. The main Control Room charcoal filter trains are designed in accordance with requirements of Regulatory Guide 1.52 "DESIGN, TESTING, AND MAINTENANCE CRITERIA FOR POST ACCIDENT ENGINEERED-SAFETY-FEATURE ATMOSPHERE CLEANUP SYSTEM AIR FILTRATION AND ADSORPTION UNITS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS" (with the exceptions noted in Updated Safety Analysis Report (USAR) Table 6.5-1). Both filter trains and associated air handling equipment are designed to Seismic Category I and are located within the main Control Room pressure boundary.

Each Control Room charcoal filter train includes an electric heating coil powered from a standby bus to limit the relative humidity of the incoming air to 70 percent at design flow during post-LOCA'conditions. The charcoal filter train air heater is automatically energized if neither the high filter air temperature cutout nor the low filter air flow cutout have been activated.

Control Room Charcoal Filter Heaters (HVC*FLT3AH/3BH) are powered from Division I and II standby Engineered safety System (ESF) buses respectively. USAR Tables 8.3-2a and 8.3-2b show that these heaters each have a nameplate rating of 23 kW.

The current TS is based on the name plate data and not the design requirement. This change provides a calculated value for the heater to perform its design function rather than the nameplate value. This new acceptance criterion is more representative and will provide improved operational reliability and flexibility.

to RBG-46669 Page 3 of 4 QH = 4400- (60 minutes/hr) - (14.28) (50.2 - 47.6) = 48067 Btu/hr QH = 48067 Btu/hr- (0.2931 watts per btu/hr) = 14088 watts, or 14.088 kW Therefore, the minimum heater size was conservatively approximated as 15 kW.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any General Design Criterion (GDC) differently than described in the Updated Final Safety Analysis Report (UFSAR.) Adequate radiation protection of the Control Room under accident conditions continues to be provided in accordance with GDC 19 with a lower heater wattage requirement.

Neither Regulatory Guide 1.52 nor ASME N510-1989 specify heater acceptance criteria.

5.2 No Significant Hazards Consideration Entergy Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

This change specifies the required power (in kW) for the Control Room ventilation electric heaters to decrease relative humidity of the air to less than 70% relative humidity as required for proper operation of the charcoal absorber components based on calculated requirements. The heater will continue to perform its intended design function as designed. The heater is not an accident precursor.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

RBG-46669 Page 4 of 4 The heater will continue to perform its function as designed. The heater provides humidity control for the Control Room filter unit during a design basis accident.

Changing the test acceptance criteria to a calculated value has no influence on, nor does it contribute in any way to, the possibility of a new or different kind of accident or malfunction from those previously analyzed. No change has been made to the design, function or method of performing testing. No safety-related equipment or safety functions are altered as a result of this change.

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

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

Response: No.

No margin of safety is changed as a result of this change. The heater will continue to perform its design function. Testing methodology has not changed. The function of the heater is unchanged. The acceptance criterion has been changed to a calculated value rather than the name plate rating to make testing more realistic. The heater will continue to operate to perform its intended design function.

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

Based on the above, Entergy concludes that the proposed amendment present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. Regulatory Guide 1.52 "DESIGN, TESTING, AND MAINTENANCE CRITERIA FOR POST ACCIDENT ENGINEERED-SAFETY-FEATURE ATMOSPHERE CLEANUP SYSTEM AIR FILTRATION AND ADSORPTION UNITS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS"

2. ASME N510-1989 "Testing Of Nuclear Air Treatment Systems"

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP' (continued)

e. Demonstrate that the heaters for each of the ESF syste isAssipate the value specified below when tested in accordance wiOtCA 510-1989:

ESF Ventilation Syste~m Wattaaie fSX1 SGTS .61 kW FBVS >49 kW CRFAS 25-2,5i:

_ -. kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the main condenser offgas treatment system and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The program shall include:

a. The limits for concentrations of hydrogen in the main condenser offgas treatment system and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion); and

b. A surveillance program to ensure that the quantity, of radioactive material contained in any unprotected outdoor tank is limited to _ 10 curies, excluding tritium and dissolved or entrained noble gases.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

5.5.9 Diesel Fuel Oil Testing Prorarn A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The (continued)

RIVER BEND 5.0-13 Amendment No. "8"z.