RBG-47048, License Amendment Request, Application for Technical Specification Changes Technical Specification Task Force Improvement Standard Technical Specification Change Traveler, TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities
| ML102100188 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/22/2010 |
| From: | Mike Perito Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RBG-47048, TSTF-484 | |
| Download: ML102100188 (14) | |
Text
EnteW Entergy Operations, Inc.
River Bend Station 5485 U.S..Highway 61 N St. Francisville, LA 70775 Tel 225-381-4795 Michael Perito Vice President, Operation RBG-47048 July 22, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
License Amendment Request Application for Technical Specification Changes Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities."
River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47
Dear Sir or Madam:
In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for River Bend Station (RBS), Unit 1.
The proposed amendment would revise LCO 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 200OF as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction.
with an inservice leak or hydrostatic test, while considering operational conditions to be in MODE 4.
This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the model safety evaluation for this TS improvement was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the Consolidated Line Item Improvement Process (CLIIP). provides a description of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the existing TS Bases pages marked up to show the proposed change (for information only). provides a summary of the regulatory commitment made in this submittal.
RBG-47048 Page 2 of 2 Although this request is neither exigent nor emergency, your prompt review is requested.
Once approved, the amendment shall be implemented Within 60 days. If you have any questions or require additional information, please contact Mr. David N. Lorfing at (225) 381-4157.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 22, 2010 Sincerely, MP/DO/bmb Attachments:
- 1. Analysis of Proposed Technical Specification Change
- 2. Proposed Technical Specification Changes (mark-up)
- 3. Changes to Technical Specification Bases Pages - For Information Only
- 4. List of Regulatory Commitments cc: Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U. S. Nuclear Regulatory Commission Attn: Mr. Alan B. Wang MS 0-8 B1 Washington, DC 20555-0001 Mr. Jeffrey P. Meyers Louisiana Department of Environmental Quality Office of Environmental Compliance Attn:OEC - ERSD P. 0. Box 4312 Baton Rouge, LA 70821-4312 RBG-47048 Analysis of Proposed Technical Specification Change to RBG-47048 Page 1 of 3
1.0 DESCRIPTION
The proposed amendment would revise River Bend Station (RBS), Unit 1 Technical Specification (TS) LCO 3.10.1, "lnservice Leak and Hydrostatic Testing Operation," and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 200'F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in MODE 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF)
Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the model safety evaluation for this TS improvement was announced in the Federal Register on October 27, 2006, (71 FR 63050) as part of the Consolidated Line Item Improvement Process (CLIIP).
2.0 PROPOSED CHANGE
Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, "Inservice Leak and Hydrostatic Testing Operation."
Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS Amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program. This application is being made in accordance with the CLIIP. Entergy is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the NRC staffs model Safety Evaluation (SE) published on October 27, 2006, (71 FR 63050) as part of the CLIIP Notice of Availability.
Currently LCO 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," allows for operation with the average reactor coolant system temperature > 200'F while considering operational conditions to remain MODE 4 (i.e., < 2000F) solely to allow performance of an inservice leak or hydrostatic test provided certain secondary containment operability requirements are imposed consistent with operation in MODE 3 (i.e., > 2000F). The Bases relate that the intent of this allowance would be solely when minimum temperature limitations imposed for the hydrostatic pressure test would require operation above 200'F.
The proposed revision to LCO 3.10.1, and the associated Bases, will expand the scope to include provisions for temperature excursions > 2000F as a consequence of inservice leak or hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be MODE 4.
3.0 BACKGROUND
-The background for this application is adequately addressed by the NRC Notice of Availability of Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1 published on October 27, 2006, (71 FR 63050).
to RBG-47048 Page 2 of 3
4.0 TECHNICAL ANALYSIS
Entergy has reviewed the Safety Evaluation (SE) published on October 27, 2006, (71 FR 63050) as part of the CLIIP Notice of Availability of the Model Safety Evaluation. Entergy has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to River Bend Station, Unit 1 and therefore justify this amendment for the incorporation of the proposed changes to the River Bend Station, Unit 1, TS. No deviation from the approved standard Technical Specifications are proposed.
Entergy will establish the Technical Specification Bases for LCO 3.10.1 as adopted with the applicable license amendment, within 60 days of amendment issuance.
5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Determination Entergy has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1 published on August21, 2006, (71 FR 48561).
Entergy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to RBS, Unit 1 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability of the Model Safety Evaluation published on October 27, 2006, (71 FR 63050).
6.0 ENVIRONMENTAL CONSIDERATION
Entergy has reviewed the environmental evaluation included in the safety evaluation published on October 27, 2006, (71 FR 63050) as part of the CLIIP Notice of Availability of the Model Safety Evaluation. Entergy has concluded that the staffs findings presented in that evaluation are applicable to RBS, Unit 1 and the evaluation is hereby-incorporated by reference for this application.
7.0 REFERENCES
- 1. Federal Register Notice (71 FR 48561), dated August21, 2006, "Notice of Opportunity to Comment on Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1, Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process."
- 2. Federal Register Notice (71 FR 63050), dated October 27, 2006, "Notice of Availability of Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1, Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process."
to RBG-47048 Page 3 of 3
- 3. Federal Register Notice (71 FR 55807), dated September 25, 2006, "Notice of Opportunity to Comment on Model Application on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1, Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process.:'
- 4. Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-484 "Use of TS 3.10.1 for Scram Time Testing Activities, Revision 0."
RBG-47048 Proposed Technical Specification Changes (mark-up)
Note, markup deletions identified by strikethrough (delete) and additions identified by underline (addition).
Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," may be suspended, to allow pe-f*f..an..
of an in.er, Ic leak Or hydrOtatic test provided the following MODE 3 LCOs arc met: reactor coolant temperature > 200 F:
For te-allew performance of an inservice leak or hydrostatic test, As a consequence of maintaininq adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in coniunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:
- a.
LCO 3.3.6.2, "Secondary Containment and Fuel Building Isolation Instrumentation," Functions 1, 2, and 5 of Table 3.3.6.2-1;
- b.
LCO 3.6.4.1, "Secondary Containment-Operating";
- c.
LCO 3.6.4.2, "Secondary Containment Isolation Dampers (SCIDs) and Fuel Building Isolation Dampers (FBIDs)";
- d.
LCO 3.6.4.3, "Standby Gas Treatment (SGT) System"; and
- e.
LCO 3.6.4.5, "Fuel Building."
APPLICABILITY:
MODE 4 with average reactor coolant temperature > 2000F.
RIVER BEND 3.10-1 Amendment No. 8-1-4 1-3,44-RBG-47048 Changes to Technical Specification Bases Pages For Information Only Note, markup deletions identified by strikethrough (delete) and additions identified by underline (addition).
B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 200OF (normally corresponding to MODE 3), or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 2000F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 200'F when the control rod scram time testing is initiated in coniunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordancewith LCO 3.10.4, "Single Control Rod Withdrawal-Cold Shutdown," during MODE 4 operation.
Inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going.
critical after a refueling outage. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.11, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.
With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure. Periodic updates to the RCS P/T limit curves are performed as necessary, based on the results of analyses of irradiated surveillance specimens removed from the vessel.
Hydrostatic and leak testing will may eventually be required with minimum reactor coolant temperatures > 2000F. However, even with required minimum reactor coolant temperatures < 2000F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation.
Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.
The hydrostatic and/or RCS system leakage tests requires increasing pressure to approximately 1055 psig., Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures > 950 psig.
Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.
RIVER BEND B 3.10-1 Revision No. 0
APPUCABLE SAFETY ANALYSES Allowing the reactor to be considered in MODE 4 during hydrotatic Orleoak tess&tn,-when the reactor coolant temperature is > 2001F, during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in coniunction with an inservice leak or hydrostatic test, effectively provides an exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems (ECCS). Since the hydrFstatci-er-leak tests are performed nearly water solid, at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the limits of LCO 3.4.8, "Reactor Coolant System (RCS) Specific Activity," are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing.
The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.
In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate.
The capability of the low pressure coolant injection and low pressure core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS -Shutdown,"
would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.
For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.
As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply.
Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures > 2001F, can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures (continued)
RIVER BEND B 3A10-2 R Revision No. 0
BASES LCO (continued)
> 2001F, while the ASME inservice test itself requires the safety/relief valves to be gagged, preventing their OPERABILITY. Additionally, even with required minimum reactor coolant temperatures < 2000F, RCS~temperatures may drift above 200'F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of others tests and inspections is not precluded.
If it is..desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures > 2001F for the purposes of performing eitheF an inservice leak or hydrostatic test and for control rod scram time testing initiated in coniunction with an inservice leak or hydrostatic test.
This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements. that-are-in effeet immediately prior to and immediately after this epcratin APPLICABILITY The MODE 4 requirements may only be modified for the performance of, or as a consequence of, inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing initiated in coniunction with an inservice leak or hydrostatic test, so that these operations can be considered as in MODE 4, even though the reactor coolant temperature is > 2000F. The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.
ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the (continued)
RIVER BEND B 3.10-3 Revision No. 0 1
RBG-47048 List of Regulatory Commitments to RBG-47048 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE (Check one)
SCHEDULED ONE-CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE ACTION Entergy will establish the Technical Specification X
Within 60 Bases for LCO 3.10.1 as adopted with the days of applicable license amendment.
amendment issuance