ML12341A003
| ML12341A003 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 12/05/2012 |
| From: | Wang A Plant Licensing Branch IV |
| To: | Burmeister B, Williamson D Entergy Operations |
| Wang A | |
| References | |
| TAC ME7767 | |
| Download: ML12341A003 (2) | |
Text
1 Burkhardt, Janet From:
Wang, Alan Sent:
Wednesday, December 05, 2012 3:13 PM To:
BURMEISTER, BARRY M; WILLIAMSON, DANNY H Cc:
Burkhardt, Janet; Lent, Susan
Subject:
TS Table 3.3.8.1 License Amendment Request (ME7767)
Barry and Danny, by letter dated December 8, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11349A246) supplemented by letter dated September 5, 2012, (ADAMS Accession No. ML12255A170) and e-mail dated October 16, 2012 (ADAMS Accession No. ML12291A763),
Entergy Operations, Inc. (the Licensee) made a license amendment request (LAR) for River Bend Station, Unit
- 1. The LAR requests amendment of the Technical Specifications (TS) to (1) extend the frequency of the Surveillance Requirements (SR) 3.3.8.1.3 for calibration of Loss of Power Instrumentation from 18 to 24 months, and (2) revise following allowable values in TS Table 3.3.8.1, Loss of Power Instrumentation, necessary to address the discovery of a non-conservative AVs in TS Table 3.3.8.1:
A.
Division 1 and 2 - 4.16 kV Emergency Bus Undervoltage:
Function 1.a, Loss of Voltage - 4.16 kV basis, add AV > 3005 V and < 3302 V (Note 1)
Function 1.d, Degraded Voltage - Time Delay, No LOCA, add AV > 46.59 seconds and < 57.07 seconds (Note 1)
B.
Division 3 - 4.16 kV Emergency Bus Undervoltage:
Function 2.a, Loss of Voltage - 4.16 kV basis, add AV > 3019 V and < 3325 V (Note 1)
Function 2.d, Degraded Voltage - Time Delay, No LOCA, add AV > 44.7 seconds and < 54.82 seconds (Note 1)
(Note 1 - These values become effective as of the end of RF17)
In response to NRC staff request for additional information by e-mail dated October 16, 2012, the licensee provided the following calculations including a white paper:
O Calculation No. G13.18.6.2-ENS_007_EC40339 O Calculation No. G13.18.3.1_005_EC40339 O Calculation No. G13.18.6.2-ENS_002_EC40339 O Calculation No. G13.18.6.2-ENS_004_EC40339 O Calculation No. G13.18.6.2-ENS_006_EC40339 O Calculation No. G13.18.3.1_004_EC40339 O RBS Methodology (white paper)
The NRC staff has determined that the additional information specified below is needed to complete our safety evaluation:
- 1. In Calculation No. G13.18.6.2-ENS_007_EC40339 the licensee calculated the as-left tolerance (ALT) as 80% of the as-found tolerance (AFT) of + 1.685 seconds because the ALT calculated based on vendor provided data was greater than the AFT calculated based on plant specific drift evaluation data.
For three other calculations (G13.18.6.2-ENS_002_EC40339, G13.18.6.2-ENS_004_EC40339, and G13.18.6.2-ENS_006_EC40339), the ALTs were determined to be significantly less than
2 80% of the AFT values for the same instruments.
Provide justification for selecting ALT to be 80% of AFT in the first calculation. Include in your justification a description regarding how the effects of device accuracy (including repeatability, linearity, and hysteresis), measurement and test equipment (M&TE) accuracy, and M&TE readability have been enveloped in the 80% of AFT value calculated. Show that for the calculation of AFT, the magnitude of AFT is sufficient to account for the value of ALT plus the drift between scheduled surveillance intervals calculated, such that if the instrument was left at the non-conservative endpoint of the ALT, there is sufficient margin to account for the drift calculated.
- 2. Please provide example marked-up procedure sections that identify the values for TS, TRM, as-found, as-left and define the source for these values. The example may be limited to one markup of a table that has TS and TRM limits and a table with only TS limits. For the markup describe the site actions when as-found value is outside each of the expected limits. Describe the actions if the item cannot be reset to within the as left conditions.
- 3. Justify the assumption that vendor data (as found in specifications sheets or manuals) is bounding for the 95/95 tolerance limits of supplied component parameters.
This request was discussed with Mr. Danny Williamson of your staff on December 5, 2012, and it was agreed that a response would be provided by December 19, 2012. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1445 or via e-mail at Alan.Wang@nrc.gov.
Alan Wang Project Manager (River Bend Station)
Nuclear Regulatory Commission Division of Operating Reactor Licensing