RBG-47163, Supplement to License Amendment Request Application for Technical Specification Changes Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-427, Allowance For..
| ML11214A092 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/27/2011 |
| From: | Roberts J Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RBG-47163 | |
| Download: ML11214A092 (10) | |
Text
Entergy8 Entergy Operations, Inc.
River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4374 Jerry C. Roberts Director, Nuclear Safety Assurance RBG-47163 July 27, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Reference Supplement to License Amendment Request Application for Technical Specification Changes Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-427, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY."
River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47 RBG-47146, "Application for Technical Specification Changes Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-427, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY."
Dear Sir or Madam:
On June 10, 2011 Entergy Operations, Inc. (Entergy) submitted a request for an amendment to the Technical Specifications (TS) for River Bend Station (RBS), Unit 1.
The proposed amendment adds a new LCO Applicability requirement, LCO 3.0.9, and its associated Bases, to address barriers which cannot perform their related support function for Technical Specification systems. Due to an internal administrative error the proposed mark-up of a Technical Specification page and associated TS Bases page were not included with the submittal.
The initial submittal identified that Entergy accepts the full scope of TSTF-427 with no deviations. As a result the omission should not modify the scope of the submittal or the No Significant Hazard evaluation. A discussion with the NRC Project Manager on July 21, 2011 also concluded a supplemental submittal is appropriate.
C)JJ
RBG-47163 Page 2 of 2 provides the existing TS pages marked up to show the proposed changes. provides the existing TS Bases pages marked up to show the proposed change (for information only). The pages in Attachments 1 and 2 include the initial submittal and the omitted portions, There are no new commitments in this letter. If you have any questions or require additional information,-please contact Mr. Barry M. Burmeister at (225) 381-4148.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 27, 2011 Sincerely, Attachments:
- 1. Proposed Technical Specification Changes (mark-up)
- 2. Changes to Technical Specification Bases Pages - For Information Only 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. O. 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-47163 Proposed Technical Specification Changes (mark-up)
Note, markup deletions identified by strikethrough (delete) and additions identified by underline (addition).
to RBG-47163 Page 1 of 2 LCO Applicablity 3-0 3-0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3-0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.-0Z ZCO 3_Q_
and LCO 3.02;L.
LCO 3.0-2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
- a.
MODE 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;
- b.
MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and
- c.
MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 310.3 is only applicable in MODES 1, 2, and 3.
LCO 3-0-4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- a.
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; (continued)
RIVER BEND 3.0-1 Amendment No. 84-, 4 1
to RBG-47163 Page 2 of 2 LCO Appicablity 3.0 3.0 LCO APPLICABILITY (continued)
LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.
LCO 3.0.8 Not Used LCO 3.0.9 When one or more resuired batiers are unable to perform their related sunoort function(sl, any suosorted system LCO(s) are not recuired to be declared not met solely for this reason for uo to 30 days orovided that at least one train or subsystem of the supported system is OPERABLE and sunnorted by barriers canable of orovidino their related support function(s), and risk is assessed and managed. This specificaltion may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.
For the purposes of this snecificabon, the High Pressure Core Spray system. the Reactor Core Isolation Cooling system, and the Automatic Depressurization System are considered independent subsystems of a single system.]
If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored 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 the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related sup port function(s).
At the end of the specified period, the required barriers must be able to perform their related support functions) or the supported system LCO(s) shall be declared not met RIVER BEND 3.0-3 Amendment No.U I
RBG-47163 Changes to Technical Specification Bases Pages For Information Only -
Note, markup deletions identified by strikethrough (delete) and additions identified by underline (addition).
to RBG-47163 Page 1 of 4 LCO Applicability B3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3-0.1 through LCO 3.0.9-7 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3-0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (iLe., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3-0-2 LCO 3-0-2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met-This Specification establishes that
- a.
Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
- b.
Completion of the Required Actions is not required when an LCO is met within the specified Completion lime, unless otherwise specified-There are two basic types of Required Actions. The first t'ype of Required Action specifies a time limit in which the LCO must be met This time limrit is the Completion lime to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion lime, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the (continued)
RIVER BEND B 3-0-1 Revision No.-@ I to RBG-47163 Page 2 of 4 LCO Applicability B 3.0 BASES LCO 3.0.7 demonstrate select unit performance characteristics, to perform special (continued) maintenance activities, and to perform special evolutions. Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.
The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS.
Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO's ACTIONS may direct the other LCO's ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.
LCO 3.0.8 Not Used LCO 3.0.9 LCO 3.0.9 establishes conditions under which systems described in the Technical Specifications are considered to remain OPERABLE when required barriers are not capable of providlng their related support function(s).
Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications, that support the performance of the safety function of systems described in the Technical Specifications. This LCO states that the supported system is not considered to be inoperable solely due to required barriers not capable of performing their related supoort (continued)
RIVER BEND B 3.0-9_
Revision No. G_-
I to RBG-47163 Page 3 of 4 LCO Applicability B 3.0 BASES LCO 3.0.9 function(s) under the described conditions. LCO 3.0.9 allows 30 days (continued) before declaring the supported system(s) inoperable and the LCO(s) associated with the supported system(s) not met. A maximum time is placed on each use of this allowance to ensure that as required barriers are found or are otherwise made unavailable, they are restored. However, the allowable duration may be less than the specified maximum time based on the risk assessment.
If the allowed time expires and the barriers are unable to Perform their related support function(s), the supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.
This provision does not apply to barriers which support ventilation systems or to fire barriers. The Technical Specifications for ventilation systems provide specific Conditions for inoperable barriers. Fire barriers are addressed by other regulatory requirements and associated plant programs. This provision does not apply to barriers which are not required to support system OPERABILITY (see NRC Regulatory Issue Summary 2001-09. "Control of Hazard Barriers," dated Apdl 2. 2001).
The provisions of LCO 3.0.9 are lustified because of the low risk associated with required barriers not being capable of performing their related suooort function. This provision is based on consideration of the following initiating event cateqories:
" Loss of coolant accidents:
" Feedwater line breaks;
" Internal flooding:
" External flooding:
Turbine missile ejection; and Tornado or high wind.
The risk impact of the barriers which cannot Perform their related suPPort function(s) must be addressed Pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65 (a)(4), and the associated implementation guidance, Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
(continued)
RIVER BEND B310-9_
Revision No. 0 1
to RBG-47163 Page 4 of 4 LCO Applicability
- B 3.0 BASES LCO 3.0.9 This guidance provides for the consideration of dynamic plant (continued) configuration issues, emergent conditions, and other aspects pertinent to plant operation with the banriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory actions being required during the Period that barriers are unable to Perform their related support function(s).
LCO 3.0.9 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example. LCO 3.0.9 may be applied for up to 30 days for more than one train of a multiple train supported system if the affected barrier for one train protects against internal flooding and the affected barrier for the other train protects against tornado missiles. In this example, the affected barrier may be the same physical barrier but serve different protection functions for each train.
The HPCS (High Pressure Core Spray) and RCIC (Reactor Core Isolation Cooling) systems are single train systems for iniecting makeup water into the reactor during an accident or transient event. The RCIC system is not a safety system, nor reauired to operate during a transient, therefore, it does not have to meet the single failure criterion. The HPCS system provides backup in case of a RCIC system failure. The ADS (Automatic Depressurization System) and low pressure ECCS coolant iniection provide the core cooling function in the event of failure of the HPCS system during an accident. Thus, for the purposes of LCO 3.0.9, the HPCS system, the RCIC system, and the ADS are considered independent subsystems of a single system and LCO 3.0.9 can be used.
on these single train systems in a manner similar to multiple train or subsystem systems.]
If during the time that LCO 3.0.9 is being used, the required OPERABLE train or subsystem becomes inoperable, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the train(s) or subsystem(s) supported by barriers that cannot perform their related support function(s) must be declared inoperable and the associated LCOs declared not met. This 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period provides time to respond to emergent conditions that would otherwise likely lead to entry into LCO 3.0.3 and a rapid plant shutdown, which is not justified given the low probability of an initiating event which would require the barrier(s) not capable of performing their related support function(s). Duringq this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the plant risk associated with the existing conditions is assessed and managed in accordance with 10 CFR 50.65(a)(4).
RIVER BEND B 3.0-9 Revision No. 0- I