ML14149A484
| ML14149A484 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/29/2014 |
| From: | Wang A Plant Licensing Branch IV |
| To: | Burmeister B Entergy Nuclear Operations |
| References | |
| MF3601 | |
| Download: ML14149A484 (5) | |
Text
1 NRR-PMDAPEm Resource From:
Wang, Alan Sent:
Thursday, May 29, 2014 1:22 PM To:
BURMEISTER, BARRY M; WILLIAMSON, DANNY H Cc:
Joseph Clark (JCLARK@entergy.com); Burkhardt, Janet
Subject:
RIVER BEND STATION, UNIT 1 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQ LIC ACTION, LAR TO REV UFSAR TO CREDIT ULTIMATE HEAT SINK (TAC NO. MF3601)
Attachments:
NonAccept to licensee 5-29.docx Barry and Danny, By letter dated February 10, 2014 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML14051A170), Entergy Operations, Inc. (Entergy, the licensee), submitted a license amendment request for the River Bend Station, Unit 1 (RBS). The proposed amendment would revise the Updated Final Safety Analysis Report (UFSAR) to credit makeup to the ultimate heat sink in less than 30 days to account for system leakage and for operation with more than one division of standby service water in operation. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the U.S. Nuclear Regulatory Commission (NRC) staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of the Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.43 of 10 CFR addresses the content of the technical information required. This section stipulates the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that additional information is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment. The requested information is attached.
In order to make the application complete, the NRC staff requests that Entergy supplement the application to address the information requested by May 30, 2014. This will enable the NRC staff to complete its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC staff will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.
The information requested and associated time frame in this letter were discussed with Mr. Danny Williamson of your staff on May 17, 2014.
If you have any questions, please contact me at (301) 415-1445 or Alan.Wang@nrc.gov.
Alan B. Wang, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Hearing Identifier:
NRR_PMDA Email Number:
1318 Mail Envelope Properties (Alan.Wang@nrc.gov20140529132200)
Subject:
RIVER BEND STATION, UNIT 1 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQ LIC ACTION, LAR TO REV UFSAR TO CREDIT ULTIMATE HEAT SINK (TAC NO. MF3601)
Sent Date:
5/29/2014 1:22:25 PM Received Date:
5/29/2014 1:22:00 PM From:
Wang, Alan Created By:
Alan.Wang@nrc.gov Recipients:
"Joseph Clark (JCLARK@entergy.com)" <JCLARK@entergy.com>
Tracking Status: None "Burkhardt, Janet" <Janet.Burkhardt@nrc.gov>
Tracking Status: None "BURMEISTER, BARRY M" <BBURMEI@entergy.com>
Tracking Status: None "WILLIAMSON, DANNY H" <DWILL21@entergy.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 3051 5/29/2014 1:22:00 PM NonAccept to licensee 5-29.docx 36206 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Enclosure SUPPLEMENTAL INFORMATION REQUEST LICENSE AMENDMENT REQUEST TO REVISE UPDATED FINAL SAFETY ANALYSIS REPORT TO CREDIT ULTIMATE HEAT SINK ENTERGY OPERATIONS, INC.
RIVER BEND STATION, UNIT 1 DOCKET NO. 50-458 By letter dated February 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14051A170), Entergy Operations, Inc. (Entergy, the licensee),
submitted a license amendment request (LAR) for the River Bend Station, Unit 1 (RBS). The LAR was submitted for a revision made to the Updated Final Safety Analysis Report (UFSAR) in 2002, which credits makeup to the ultimate heat sink (UHS) to account for system leakage and for operation with more than one division of standby service water (SSW). The UHS capacity is to last 30 days after a design-basis accident (DBA), but with system leakage and operation of more than one division of SSW (maximum safeguards conditions), it lasts only 22 days without makeup. The LAR was submitted in response to a violation issued by the U.S. Nuclear Regulatory Commission (NRC) for the UFSAR change in 2002 without prior NRC approval.
The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of the Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.43 of 10 CFR addresses the content of the technical information required. This section stipulates the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated below is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment.
- 1.
The licensee states that the UHS is capable of meeting the Regulatory Guide 1.27 guideline for 30-day inventory without makeup, considering no system leakage. In addition, the licensee states system leakage was not part of the license basis and thus the the ability to provide makeup to the UHS in less than 30 days is only credited for non-design basis scenarios and therefore does not result in a failure of the UHS basin.
The NRC staffs position is that the fully functioning system that does not adversely affect design requirements (last for 30 days without makeup) is part of the licensing
basis by implication. System degradation or performance to a point where the system does not meet its design function means that the system is not meeting the design basis and licensing basis. The licensee has not stated in the LAR whether the system is degraded. Please explain if the system is degraded (somewhere in UHS/SSW) because of the leakage (and/or other reasons) as it cannot perform its design function without makeup.
- 2.
The application identifies system leakage as reducing the amount of UHS capacity after DBA from 30 days to 22 days. The application does not identify the location and quantity of system leakage and whether the system is degraded.
A.
Please identify whether the UHS and/or SWS is degraded and provide the basis for the operability determination.
B.
Please discuss how you have quantified system leakage and identified leakage locations. If the system is degraded, explain why leakage is not repaired.
- 3.
The UFSAR change as shown in Attachment 3, which is the subject of the LAR, lists primary and alternate methods of adding water to the UHS basin after 22 days post DBA to make up for system leakage. Also, in answering the significant hazards analysis required by 10 CFR 50.92, the licensee has answered no to the question whether the LAR significantly increases the consequences of an accident previously evaluated, with the justification that adequate makeup sources are available within the approximate 22 day time frame. But the licensee has provided no justification as to why the makeup sources are adequate to compensate for a SSW/UHS system that does not leak.
A.
Please provide justification of the availability of these makeup methods with respect to availability considering ability to withstand seismic and weather related events including tornadoes and tornado missiles and reliability of electric power sources. Identify time and resources to implement each method, describe flow path and SSC involved, and describe freedom of movement to implement alternate methods after a DBA.
- 4.
According to Attachment 1, the 2002 UFSAR revision was made to account for operation with more than one division of SSW in operation because one emergency diesel generator (EDG) may not fail as a single failure (i.e. all EDGs may be available after a DBA).
A.
Please explain why this issue became pertinent circa 2002 and why this accounting was not previously considered.
B.
Please explain how this scenario affects peak UHS basin temperature and associated limits.
C.
Please explain how and why accounting for two trains of service water was not originally part of the design basis for determining UHS required capacity. Revise UFSAR UHS design basis to include use of two trains for a specified duration after a DBA if appropriate.
- 5. identifies that the licensee made non-conservative assumptions regarding pump heat which slightly increase loss from the UHS basin after a DBA. Attachment 4 addresses these assumptions vaguely by stating that these assumptions are inconsistent with the actual methodology. Attachment 4 further states that these assumptions have no adverse impact on the operation of the associated pumps and that the 30-day inventory can be met. The technical information provided is vague such that the NRC staff has no technical input to address the issues in a safety evaluation.
A.
Please identify and explain the non-conservative assumptions and inconsistencies in methodology and explain how the revised calculation has removed the inconsistencies in the methodology and non-conservatisms as well as other non-compliant items.