RBG-47176, Supplemental Information Changes to Technical Specification 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation

Supplemental Information Changes to Technical Specification 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation

ML11263A013
Person / Time
Site:	River Bend
Issue date:	09/16/2011
From:	Clark J Entergy Corp, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-47176, TAC ME6843
Download: ML11263A013 (16)

Text

9L IEnteigya Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4374 Joseph A. Clark Manager, Licensing RBG-47176 September 16, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

REFERENCES:

Supplemental Information Changes to Technical Specification 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47

1. Entergy Letter to NRC dated July 27, 2011, License Amendment Request, Changes to Technical Specification 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" (RBG-47157)

2. NRC letter to Entergy dated September 1, 2011, Supplemental Information Needed For Acceptance Of Requested Licensing Action Re: Request To Modify Main Steam Tunnel Temperature Function (TAC NO. ME6843)

Dear Sir or Madam:

On July 27, 2011 Entergy Operations, Inc. (Entergy) submitted a request for a amendment to the Technical Specifications (TS) for River Bend Station (RBS), Unit 1. A change is proposed to Technical Specification (TS) 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" to revise the allowable value setpoints for the Main Steam Tunnel Temperature functions 1.e, 3.f and 4.h (Reference 1).

The NRC requested additional information on September 1, 2011. Entergy's response to this request is provided in Attachment 1.

There are no new commitments in this letter.

A,0 r3I

RBG-47176 Page 2 of 3 If you have any questions or require additional information, please contact me at (225) 381-4177.

Sincerely, JAC/bmb Attachments:

1. Response to Supplemental Information Needed 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 Louisiana Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning & Response Section JiYoung Wiley P. 0. Box 4312 Baton Rouge, LA 70821-4312 RBG-47176 Response to Supplemental Information Needed to RBG-47176 Page 1 of 13 On September 1, 2011, the NRC requested the following:

1. The LAR described the proposed change for the AV for the Main Steam Tunnel Temperature. This LAR also referenced the approved setpoint methodology used to determine the new AV. However, the LAR does not include a summary calculation of the setpoint methodology used for determining the AV for the Main Steam Tunnel Temperature functions to enable the NRC staff to verify if the calculation adheres to the approved methodology.

Response

The following information provides a summary of the calculation (G13.18.6.1-E31*009) performed in support of the requested change to the main steam tunnel isolation temperature setpoint.

to RBG-47176 Page 2 of 13 REVISION

SUMMARY

to G13.18.6.1-E31*009 Rev Required Changes to Achieve Revision 0

Initial Issue 11

a. Changed Allowable Value (AV) and Nominal Trip Setpoint (NTSP).

b. Added RBS USAR Table 9.4-1 as a reference since it is cited in an assumption.

c. Revised wording of an assumption and added the Qualification Test Document as a reference in support of the revised assumption.

d. Updated environmental zone values.

e. Made minor editorial changes.

1Revision pending incorporation of Engineering Change Markup EC-25039.

RBS: River Bend Station USAR: Updated Safety Analysis Report Contents:

This document is a supplement analysis data sheet to Reference 1. Included in this document in sequential order are:

The setpoint functions for the system, The setpoint function analyses inputs and the source reference of the inputs, The devices in the setpoint function instrument loop, The component analysis inputs and input sources, The calculated results, Input comments and result recommendations (if any),

References.

System: Leak Detection The following setpoint functions are included in this document:

Main Steam Line Tunnel High Ambient Temperature Isolation to RBG-47176 Page 3 of 13

1.0 Function

Isolation of Main Steam Lines, Reactor Core Isolation Cooling lines, and Reactor Water Cleanup lines on high Main Steam Line Tunnel ambient temperature.

Setpoint Characteristics Definition Comment(s)

Event Protection:

Limiting event for the setpoint:

Ref. 5.4.2 Main Steam Line Tunnel Ambient Temperature

- High is provided to detect a steam leak equivalent to 25 gpm outside containment and isolate the Main Steam (MS) lines, Reactor Core Isolation Cooling (RCIC) lines, and Reactor Water Cleanup (RWCU) lines. The isolation of these systems occurs when a small leak is detected. If the small leak is allowed to continue without isolation, offsite dose limits may be reached. However, credit for these instruments is not taken in any transient or accident analysis in the USAR, since bounding analyses are performed for large breaks such as MSLBs.

Function After Earthquake M] Yes El No Setpoint Direction Z] Increasing El Decreasing Single or Multiple Channel El Single

[] Multiple LER Calculation Basis if Standard (Conservative) LER Calculation [] or Multiple Channel Configuration Specific LER Calculation El Trip Logic for N/A Configuration Specific LER Calculation.

MSLBs: Main Steam Line Breaks LER: Licensee Event Report N/A: Not Applicable Current Function Value Value Comment(s)

Limits:

Present Calculation Revised Calculation Analytical Limit (AL) 194.7 OF 194.7 OF Comment 4.1 Tech Spec Allowable

<148.5 OF

• 183.0 OF Comment 4.2 Value (AV)

Nominal Trip Setpoint 144.0 OF 173.0 OF Comment 4.2 (NTSP)

Operational Limit Not Required Not Required to RBG-47176 Page 4 of 13 Plant Data:

Value Value Sigma if Comment(s)

Present Revised not 2 Calculation Calculation Primary Element (Thermocouple)

+0.0 OF

+/-0.0 OF

" Accuracy (PE)

N/A N/A Comment 4.3

• Drift (DRT/c)

Comment 4.4 Process Measurement Uncertainty (PM)

" Bias N/A N/A

" Random N/A Comment 4.5 Components or (Devices) in Setpoint Function Instrument Loop:

Thermocouple (Transmitter)

Temperature Switch (Trip Unit) 2.0 Components 2.1 Themocouple Component Information:

Value/Equation Comment(s)

Plant Instrument ID No.

E31-T/CN031A, B, C, and D Instrument Vendor PYCO Model ID No. (including Range 145C3224P002 Code)

(PYCO# 102-9039-11)

Plant Location(s)

Auxiliary Bldg: AE 3.0, 124' El.

Auxiliary Bldg: AE 4.0, 120' El.

Auxiliary Bldg: AJ 3.0, 128' El.

Auxiliary Bldg: AJ 4.0, 119' El.

Process Element Thermocouple to RBG-47176 Page 5 of 13 Inputs:

Vendor Specifications:

Value/Equation Sigma if Comment(s) not 2 Primary Model ID 145C3224P002 (PYCO# 102-9039-11)

Top of Scale 350.0 OF Bottom of Scale 40.0 OF Upper Range Limit 350.0 OF Accuracy

+ 3.060 OF Temperature Effect N/A Seismic Effect N/A Comment 4.6 Radiation Effect N/A Comment 4.7 Humidity Effect N/A Comment 4.8 Power Supply Effect N/A Comment 4.9 RFI/EMI Effect Negligible Comment 4.10 Insulation Resistance Effect

+ 0.155 OF Comment 4.11 Over-pressure Effect N/A Comment 4.12 Static Pressure Effect N/A Comment 4.13 Mounting Position Effect N/A Plant Data:

Value Comment(s)

Calib. Temperature Range 40 to 140 OF CaIc. Ref. 3.3 Normal Temperature Range 40 to 140 OF Calc. Ref. 3.3 Trip Temperature Range 135 to 320 OF (Accident)

CaIc. Ref. 3.3 Plant Seismic Value

< 3g CaIc. Ref. 3.12 Plant Radiation Value 3.3E7 Rads (Normal)

CaIc. Ref. 3.3 (Total Integrated Dose) 3.4E7 Rads (Accident)

Plant Humidity Value 20 to 95% (Normal)

CaIc. Ref. 3.3 100% All Steam (Accident)

Power Supply Variation Value N/A Comment 4.9 RFI/EMI Value Negligible domment 4.10 Over-pressure Value N/A Comment 4.12 Static Pressure Value N/A Comment 4.13 CaIc. Ref.: Corresponding Reference number in Calculation to RBG-47176 Page 6 of 13 Drift:

Value Sigma if Comment(s)

Drift:

Value Sigma if not 2 Comment(s)

Current Calib. Interval 30 Mo. lxl Includes extra 25%

N/A Ref. 5.4.1 Desired Calib. Interval N/A N/A Drift Source El Vendor N] Calculated N/A Comment 4.4 Drift Value N/A N/A Comment 4.4 to RBG-47176 Page 7 of 13 Calibration:

Value/Equation Sigma if Comment(s) not 3 As Left Tolerance (ALT)

+ 2.0 OF Comment 4.14 Leave Alone Tolerance (same as ALT)

Input Calibration Tool:

N/A Accuracy Resolution/Readability Minor Division Upper Range Temperature Effect Input Calibration Standard:

N/A Accuracy Resolution/Readability Minor Division Upper Range Temperature Effect Output Calibration Tool:

Altek Model 322-1 Thermocouple/Millivolt Calibrator Accuracy

+ (0.008% Rdg. + 0.0006 mV)

Ref. 5.5.2 Resolution/Readability Not required Comment 4.15 Minor Division Not required Comment 4.15 Upper Range Not required Comment 4.15 Temperature Effect Not required Comment 4.15 Output Calibration Standard:

N/A Accuracy Resolution/Readability Minor Division Upper Range Temperature Effect to RBG-47176 Page 8 of 13 2.2 Temperature Switch Component Information:

Value/Equation Comment(s)

Plant Instrument ID No.

E31-TSN604A, B, C, D, E, and F Instrument Vendor NUS Model ID No. (including Range NUS-A076PA-1 Code)

Plant Location(s)

Control Building 136' El.

(Main Control Room)

Process Element N/A Inputs:

Vendor Specifications:

Value/Equation Sigma if Comment(s) not 2 Primary Model ID NUS-A076PA-1 Top of Scale 350.0 OF Bottom of Scale 40.0 OF Upper Range Limit 350.0 OF Accuracy

+ 1.0 OF Temperature Effect

+/- 3.0 OF Seismic Effect N/A Comment 4.16 Radiation Effect N/A Comment 4.17 Humidity Effect N/A Comment 4,18 Power Supply Effect

+ 1.0 OF Comment 4.19 RFI/EMI Effect Negligible Comment 4.20 Insulation Resistance Effect N/A Comment 4.21 Over-pressure Effect N/A Comment 4.12 Static Pressure Effect N/A Comment 4.13 Mounting Position Effect N/A to RBG-47176 Page 9 of 13 Plant Data:

Value Comment(s)

Calib. Temperature Range 65 to 85 OF Cabc. Ref. 3.3 Normal Temperature Range 65 to 85 OF Calc. Ref. 3.3 Trip Temperature Range 65 to 85 OF Calc. Ref. 3.3 Plant Seismic Value

< 3g Calc. Ref. 3.8 Plant Radiation Value 8E2 Rads (Normal)

Calc. Ref. 3.3 N/A (Accident)

Plant Humidity Value 20 to 75% (Normal)

Calc. Ref. 3.3 Same as Normal (Accident)

Power Supply Variation Value

+/- 1.0 OF Comment 4.19 RFI/EMI Value Negligible Comment 4.20 Over-pressure Value N/A Comment 4.12 Static Pressure Value N/A Comment 4.13 Drift:

Value Sigma if Comment(s) not 2 Current Calib. Interval 30 Mo. Zl Includes extrý 25%

N/A Ref. 5.4.1 Desired Calib. Interval N/A N/A Drift Source LW Vendor

[] Calculated N/A CaIc. Ref. 3.27 Drift Value 2.129 OF CaIc. Ref. 3.27 to RBG-47176 Page 10 of 13 Calibration:

ValuelEquation Sigma if Comment(s) not 3 As Left Tolerance (ALT)

+ 2.0 OF Comment 4.14 Leave Alone Tolerance (same as ALT)

Input Calibration Tool:

Altek Model 322-1 Thermocouple/Millivolt Calibrator Accuracy

+ (0.008% Rdg. + 0.0006 mV)

Ref. 5.5.2 Resolution/Readability Not required Comment 4.15 Minor Division Not required Comment 4.15 Upper Range Not required Comment 4.15 Temperature Effect Not required Comment 4.15 Input Calibration Standard:

N/A Accuracy Resolution/Readability Minor Division Upper Range Temperature Effect Output Calibration Tool:

N/A Accuracy Resolution/Readability Minor Division Upper Range Temperature Effect Output Calibration Standard:

N/A Accuracy Resolution/Readability Minor Division Upper Range Temperature Effect to RBG-47176 Page 11 of 13 3.0 Summary Results Calculated Values Setpoint Analytical Allowable Nominal Trip Meets LER Meets Function Limit (AL)

Value(AV)

Setpoint Avoidance Spurious (from (NTSP)

Criteria Trip Section 1)

Avoidance Criteria MSL Tunnel Ambient Tmpert 194.7 OF

_183.0 OF 173.0 OF Y

Y Temperature

- High 4.0 Comments and Recommendations 4.1 Analytical Value previously changed from 154 OF to 194.7 OF per RBS Engineering Change EC-26710 and Calculation G13.18.14.1-036.

4.2 The revised calculated values for Technical Specification Allowable Value (AV) and Nominal Trip Setpoint (NTSP) provide acceptable LER Avoidance and Spurious Trip Avoidance capability as shown in Ref. 5.3.1.

4.3 Primary Element Accuracy (PE) is the accuracy of the device (exclusive of the sensor) which is in contact with the process, resulting in some form of interaction. These thermocouples directly measure Main Steam Line Tunnel air temperature. The Temperature Switch compensates for the non-linear relationship of thermocouple temperature to millivolt output; therefore, PE is assumed to be zero.

4.4 Drift effects are considered negligible to thermocouples under normal environmental conditions. Thermocouples are static devices producing a thermal electromotive force only.

4.5 Process Measurement Uncertainties (PM) are assumed to be inherently inapplicable to thermocouples in relatively slow-moving air applications.

4.6 A seismic disturbance is assumed to have no effect on thermocouples since these devices have been successfully tested to 5g (Calc. Ref. 3.19) and the worst case seismic condition for Auxiliary Building 114' level is less than 3g (Calc. Ref. 3.12).

4.7 Radiation Effects do not apply to thermocouples since they are rated for 1 E8 RAD exposure limit per Calculation Reference 3.6.

4.8 Humidity Effects are assumed inapplicable to thermocouples since these units are rated at 20 to 100% relative humidity (Calc. Ref. 3.6) and the RBS Environmental Design Criteria (Calc. Ref. 3.3) states the relative humidity is 20 to 95% for these thermocouple locations.

4.9 Power Supply Effect is defined as "Line Voltage Effect" for this calculation. Line Voltage Effects have no impact on thermocouples since they are independent of the loop power source.

to RBG-47176 Page 12 of 13 4.10 Radio Frequency Interference (RFI)/Electromagnetic Interference (EMI) Effects are considered to have negligible impact on the manufacturer's accuracy term if it is not identified separately (Calc. Ref. 3.6).

4.11 Insulation Resistance Effects (IR), which may result in the degradation of circuit insulation, will be applied as a bias term in determining uncertainties. IR Effects are specified for RTD's in Calculation Reference 3.10 and are assumed to be the same for thermocouples as well. This is conservative in that 1) thermocouples operate with very small currents and voltages which are not significant to aid in the breakdown of the insulation and 2) the temperature at which these devices trip is significantly below the top end of their operating range and thus, the temperature condition is not severe enough to aid in the breakdown of the insulation. However, for conservatism the 0.04%

span value given in Calculation Reference 3.10 will be rounded to +0.05% span or 0.155 OF (0.05%

• 310 0F) for this calculation. IR Effects are not applicable to Temperature Switches since they are located in a mild environment.

4.12 Over Pressurization Effects (OPE) do not apply to Thermocouples or Temperature Switches since their inputs are not related to pressure.

4.13 Static Pressure Effects (SP) do not apply to Thermocouples or Temperature Switches since their inputs are not related to a sensing line or process pressure.

4.14 As Left Tolerance (ALT) as applied to instrument loop and defined as "Procedural As Left Band (PALB)" for this calculation.

4.15 Some plant specific information and Maintenance and Test Equipment (M&TE) data has not been provided in the current RBS setpoint calculation(s) or documents and is considered unnecessary because the uncertainty associated with the M&TE used in calibrating the loop components is bounded by the accuracy values included in the current RBS setpoint calculation(s) or documents.

4.16 Seismic considerations are assumed to have no effect on Temperature Switches in this calculation since the switches have been successfully tested to well above the worst case seismic condition for the Main Control Room (Calc. Ref. 3.7 and 3.8).

4.17 The Temperature Switches will not experience a harsh radiation environment (i.e., they are located in a mild environmental area and as such will be exposed to a dose which is less than the minimum required for Radiation Effects to apply).

4.18 Humidity Effects are not applicable to the Temperature Switches since these units are rated at 10 to 90% relative humidity (Calc. Ref. 3.5) and the RBS Environmental Design Criteria (CaIc. Ref. 5.5) states the relative humidity is 20 to 75% for these thermocouple locations.

4.19 Power Supply Effect is defined as "Line Voltage Effect" for this calculation. The Temperature Switches can tolerate a voltage variation of 85 to 132 VAC with a +/- 1.0 OF uncertainty (Calc. Ref. 3.5). The possible UPS and bus variation is expected to be less than the instrument requirement.

4.20 Radio Frequency Interference (RFI)/Electromagnetic Interference (EMI) Effects are considered to have negligible impact on the manufacturer's accuracy term if it is not identified separately (Calc. Ref. 3.5).

4.21 Insulation Resistance Effects are not applicable to the Temperature Switches since they are located in a mild environment.

to RBG-47176 Page 13 of 13 5.0

References:

5.1 NEDC-31336P-A, GEH Proprietary, "General Electric Instrument Setpoint Methodology"' September 1996 5.2 NEDC-31336, GEH Proprietary, "General Electric Instrument Setpoint Methodology"'

October 1986 5.3 Current applicable River Bend Station setpoint calculation:

5.3.1 G13.18.6.1-E31*009 5.4 River Bend Station Licensing and related documents:

5.4.1 RBS Technical Specifications Section 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" 5.4.2 RBS Technical Specifications Bases Section B 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" 5.4.3 RBS Technical Requirements Manual Section TR 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" 5.4.4 RBS USAR, Table 9.4-1, "Environmental and System Design Parameters for HVAC" 5.5 Applicable River Bend Station procedures/documents:

5.5.1 Engineering Change (EC) 25039 5.5.2 TCT-040A, dated November 1, 2010, "Calibration Chart Procedure" for Altek Model 322-1 Multiple Thermocouple/Millivolt Calibrator