RBG-47321, Response to Request for Additional Information on License Amendment Request 2011-05

Response to Request for Additional Information on License Amendment Request 2011-05

ML13010A385
Person / Time
Site:	River Bend
Issue date:	01/09/2013
From:	Roberts J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-47321, RBF1-13-0003
Download: ML13010A385 (13)

Text

Entergy Operations, Inc.

River Bend Station 5485 U. S. Highway 61N

'*O Entergy St. Francisville, LA 70775 Tel 225 381 4149 Fax 225 635 5068 jrober3@entergy.com Jerry C. Roberts Director, Nuclear Safety Assurance RBG-47321 January 9, 2013 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Request for Additional Information on License Amendment Request 2011-05 River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47

REFERENCES:

1. Entergy letter to NRC, dated December 8, 2011, License Amendment Request 2011-05, Degraded Voltage Surveillance Frequency Extension and Allowable Value Changes (Letter No.

RBG-47193)

2. NRC letter to Entergy (via email), dated December 5, 2012, Request for Additional Information RBF1-13-0003

Dear Sir or Madam:

On December 8, 2011, Entergy Operations, Inc. (Entergy) submitted a request to extend the frequency of a surveillance requirement and revise the allowable value for degraded voltage relays (Reference 1). During their review, the NRC staff determined that additional information is needed to complete the processing and approval of Entergy's request. The request for that information was transmitted to Entergy per Reference 2.

The attachments to this letter contain the requested information.

This letter contains no commitments. If you have any questions on this matter, please contact Joey Clark, Manager- Licensing, at 225-381-4177.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 9, 2013.

Sincerely, JCR1d NOD ý 0 q4

RBG-47321 January 9, 2013 Page 2 of 2 : Response to Request for Additional Information : Surveillance Test Procedure Markup (Example) cc: U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4511 NRC Senior Resident Inspector River Bend Station U. S. Nuclear Regulatory Commission Attn: Mr. Alan Wang MS 8-G14 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section JiYoung Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312 Public Document Room Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326

Attachment 1 RBG-47321 Response to Request for Additional Information

RBG-47321 January 9, 2013 Page 1 of 2 REQUEST No. 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 ALT's were determined to be significantly less than 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.

RESPONSE

The deviation around the desired setpoint (calculated plant specific drift) is considered the limiting value for instrument performance. In this specific case the actual performance of the device was significantly better than the vendor's stated reference accuracy or repeatability. Using the vendor's stated values of reference accuracy as had historically been done with other devices would have resulted in as-left tolerance values that would not have detected equipment degradation. Therefore, the project selected the calculated plant specific drift value as the limit of acceptability (as-found tolerance). To select an as-left value, the historical calibration data (which accounts for device accuracy, M&TE accuracy, and readability) was reviewed and a value of 80% of the AFT was selected as the As-Left tolerance. This value was readily achievable during the calibration process and provided sufficient margin to allow for detection of instrument or channel degradation.

REQUEST No. 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.

RESPONSE: provides an example of a markup to current surveillance test procedure STP-302-1605 indicating the changes for relay E22-S004-ACB1-62S6 that will be

RBG-47321 January 9, 2013 Page 2 of 2 needed for implementation of the requested amendment. Calculation G13.18.6.2-ENS*007 Section 8.11 provides the inputs for the test acceptance criteria.

The additional actions that would be taken based on the calibration as-found value are:

a. Calibration as-found value within the ALT minimum and maximum: no action is required, as-found equal to as-left and surveillance is complete.

b. Calibration as-found value outside ALT minimum and maximum but within AFT minimum and maximum: calibrate the relay to within ALT minimum and maximum, and surveillance is complete.

c. Calibration as-found value outside AFT minimum and maximum but within Technical Specification Allowable Values: calibrate relay to within ALT minimum and maximum.

Evaluate relay to verify that it is functioning as expected and would be expected to pass the next surveillance test. Initiate a Condition Report for engineering evaluation of component future operation. Surveillance is complete.

d. Calibration as-found value outside Technical Specification Allowable Values: channel is inoperable and required Technical Specification actions are taken.

e. If the relay as-left value cannot be returned to within ALT, then the device will be declared inoperable.

REQUEST No. 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.

RESPONSE

The calculation of plant specific drift validates that the Reference Accuracy, Measurement and Test Equipment Uncertainty, drift and other calibration related uncertainties are smaller than the vendor provided value. This verification indicates that the vendor values are more on the order of 99/99 limits. The verification of plant specific performance is sufficient justification to identify the input values as at least 95/95.

Attachment 2 RBG-47321 Surveillance Test Procedure Markup (Example)

CONTINUOUS USE

• G12.1.15 U - W ENTERGY RIVER BEND STATION STATION OPERATING MANUAL

• SURVEILLANCE TEST PROCEDURE

• HPCSDEGRADED VOLTA GE CHANNEL CALIBRATION AND LOGIC SYSTEM FUNCTIONAL TEST PROCEDURE NUMBER: *STP-302-1605 REVISION NUMBER: *25 Effective Date:

NOTE: SIGNATURES ARE ON FILE.

TemRev 2 AddCounter 1 Att Enc DS MSet REGULAR KWN OFF CONTINUOUS USE

• INDEXING INFORMATION

CONTINUOUS USE 4 EQUIPMENT 4.1 Measuring and Test Equipment:

NOTE Equivalency should be established based on the accuracy of a Fluke Model 45 set on 0-300VAC Range and Medium Resolution. Fluke 45 not needed if utilizing Doble F6000 series test set.

" Multimeter, Fluke 45 or equivalent with an accuracy of plus or minus 0.29% voltage reading

" Multi-Amp EPOCH 10 series, three phase test set or equivalent

" Multi-Amp EPOCH 40 series, DC/Timer test set or equivalent

" Doble F6000 or F2000 series test set or equivalent NOTE Only need 3 phase test system if bus is deenergized.

" Doble F3C, 3 Phase Test System or equivalent 4.2 Additional Equipment:

" Relay tool kit

" Burnishing tool

" ITE Circuit Card Extender Board, Catalog No. 200X0018 or 609887-T6 5 PRECAUTIONS/LIMITATIONS NOTE Equivalency should be establishedbasedon the accuracy ofa Fluke Model 45 set on 0-300VAC Range and Medium Resolution.

5.1 Unless otherwise noted, all recorded voltage data should be obtained using a digital multimeter, Fluke 45 or equivalent. Fluke 45 not needed if utilizing Doble F6000 series test sets.

STP-302-1605 REV - 25 PAGE 5 OF 51 STP-302-1605 REV-25 PAGE5OF51

CONTINUOUS USE 5.2 Where indicated, the relay should be energized for approximately 15 minutes prior to obtaining data, to allow circuits to stabilize.

Momentarily deenergizing relay will not affect data.

5.3 As-Found Section should be completed prior to any adjustments or calibrations.

NOTE Residual magnetism is defined as when the relay does not drop out when deenergized.

5.4 IF any DC relay is found to have failed due to residual magnetism, C THEN a CR describing the relay application, mark number and manufacturer part number should be generated.

C 5.5 Ensure a Condition Report is written IF the Degraded Voltage Relay (62-2) time delay (NO LOCA) setpoint is found above STP MAX.

Engineering evaluation is required IF the As-Found setpoint values are above the STP MAX limit.

C 5.6 Relays that are installed horizontally shall be tested horizontally. Relays that are installed vertically shall be tested vertically.

5.7 Removable circuit boards of solid state relays should insert smoothly.

Do not use force when reinstalling.

5.8 When removing/installing relay cover, inadvertent trip of relay could occur. Do not manipulate target reset lever when removing/installing relay cover.

5.9 When removing energized relays, components could be at elevated temperatures. Caution should be taken to prevent personnel injury.

5.10 Performance of this procedure causes Annunciator P601-16A-G01, DIVISION III DEGRADED VOLTAGE, alarm 4104 to alarm multiple times.

5.11 If Doble ProTest software is utilized to perform testing, then data can be captured electronically and transferred to surveillance.

5.12 IF E22-S004 is deenergized, THEN Sections 7.4 thru 7.7 can be performed concurrently.

C 5.13 Ensure a Condition Report is written IF the Degraded Voltage Relay (62S5 or 62S6) time delay (NO LOCA) setpoint exceeds the AFT- MAX or MIN limit but is within the Technical Specification Allowable MAX or MIN limit. Engineering evaluation is required to determine if the relay is functioning as expected.

STP-302-1605 RFV - 25 PAGE 66 OF PAGE OF 51 51 STP-302-1 605 REV -25

CONTINUOUS USE 7.7 Timing Relay 62S6 WARNING Equipment can remain energized during performance of this section of procedure. This creates the possibility of electrical shock or equipment damage. Do not perform this test without taking all necessary safety precautions for working on or near energized equipment.

7.7.1. At HPCS Bus E22-S004, Aux. cubical, remove relay 62S6.

(Initials)

1. Remove locking spring from relay.

2. Remove relay from socket.

NOTE Attachment 2, Agastat ETR Relay Test Connections, provides contact and connectionpoints.

Orientationof relay to be tested should be the same as installedin panel.

7.7.2. As-Found Test

1. Connect a 125VDC power supply to relay as follows:

1. Terminal BI positive.

(Initials)

2. Terminal B4 negative.

(Initials)

2. Connect a timer to start when DC voltage is applied to relay terminals BI & B4 and to stop automatically when relay contact M1 & TI closes.

(Initials)

3. Reset timer start circuit.

(Initials)

4. Energize 125VDC power supply.

(Initials)

STP-302-1605 REV - 25 PAGE 30 OF 51

CONTINUOUS USE NOTE Technical SpecificationAllowable value is a calculated valuefrom relays 27/62-2 and 62S6.

TS 5. WHEN timer has stopped, THEN record As-Found pickup time delay.

(Initials)

Desired Tech Spec MN As-Found M Tech Spec Allowable AFT Time Delay AFT Allowable (sec) (sec) MIN (sec) MAX (sec)

(sec) (sec) 545.0 >4. >43.8690

_-5-t-_ *7.9_

4 *40.90 45.24 >40.2 >:43.56 !546.92 _<ý49.12

6. Deenergize test circuits.

(Initials) 7.7.3. Inspect relay 62S6 and record inspection result below:

" Check that there are no cracked, broken or loose parts.

" Check that there are no signs of excessive overheating.

" Verify cleanliness.

7.7.4. Time Delay Data Comparison I. Check As-Found Data is within Non-Calibration limits listed below:

ALT MIN (sec)

ALT MAX (sec)

Sat Unsat I

>43.89 *46.59 1

2. IF As-Found data is within Non-Calibration limits, THEN Go To Step 7.7.6, As-Left Test.

(Initials)

STP-302-1605 REV - 25 PAGE 31 OF 51

CONTINUOUS USE

3. IF As-Found data is not within Non-Calibration limits, THEN Go To Step 7.7.5, Relay Calibration.

(Initials) 7.7.5. Relay Calibration NOTE Internal timing adjustmentpotentiometer is accessible through top cover of relay.

1. Adjust internal potentiometer.

(Initials)

2. Reset timer start circuit.

(Initials)

3. Energize 125VDC power supply.

(Initials)

4. WHEN timer has stopped, THEN note pickup delay time.

(Initials)

5. Deenergize test circuits.

(Initials)

6. Repeat Steps 7.7.5.1 thru 7.7.5.5 until pickup time delay is within tolerance.

(Initials)

Desired ALT MIN ALT MAX (sec) (sec) (sec) 54.90 _43i.90 *46.9 45.24 >:43.89 1<:46.59 NOTE As-Left tests areperformed to verify that adjustments made during relay inspection/calibrationhave not causedany changes to previous satisfactory data.

7.7.6. As-Left Test

1. Reset timer start circuit.

(Initials)

STP-302-1605 REV - 25 PAGE 32 OF 51

CONTINUOUS USE

2. Energize 125VDC power supply.

(Initials)

TS 3. WHEN timer has stopped, THEN record As-Left pickup time delay.

(Initials)

Desired Tech Spec ALT As-Left ALT Tech Spec Allowable MIN Time Delay MAX Allowable (see) (sec) (sec) (sec)

(sec) (sec) 545.90 490 >43.90 <46.59 <469.

45.24 >Ž40.2 Ž!43.89 _______ 46.59 *!49.12

4. Deenergize test circuits.

(Initials)

5. Disconnect relay from test equipment.

(Initials) 7.7.7. Relay Installation

1. At HPCS Bus E22-S004, Aux. cubical, inspect 62S6 relay socket and record inspection result below:

• Check that there are no signs of excessive overheating.

" Check that there are no cracks or other physical damage.

" Verify cleanliness.

" Verify all accessible fasteners are tight.

2. Reinstall relay in socket and latch locking spring on relay.

(Initials)

(CON VERIF)

STP-302-1605 REV - 25 PAGE 33 OF 51