ML14225A444

Issuance of Amendment No. 183, Revise Technical Specification Surveillance Requirements Related to Ventilation Filter Testing Program for Heaters in Safety-Related Charcoal Filter Trains

ML14225A444
Person / Time
Site:	River Bend
Issue date:	12/12/2014
From:	Wang A Plant Licensing Branch IV
To:	Entergy Operations
Wang A
References
TAC MF3014
Download: ML14225A444 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 12, 2014 Vice President, Operations Entergy Operations, Inc.

River Bend Station 5485 US Highway 61 N St. Franci,sville, LA 70775

(

SUBJECT:

RIVER BEND STATION, UNIT 1 -ISSUANCE OF AMENDMENT RE:

REVISION OF THE VENTILATION FILTER TESTING PROGRAM AND ASSOCIATED SURVEILLANCE REQUIREMENTS (TAC NO. MF3014)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 183 to Facility Operating License No. NPF-47 for the River Bend Station, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 4, 2013.

The amendmenrrevises TS Sections 3.6.4.3, "Standby Gas Treatment (SGT) System," 3.6.4.7, "Fuel Building Ventilation System- Fuel Handling," 3.7.2, "Control Room Fresh Air (CRFA)

System," and 5.5.7, "Ventilation Filter Testing Program (VFTP). Specifically, the amendment eliminates the operability and Surveillance Requirements for the heaters in the safety-related charcoal filter trains in those systems, and revises certain charcoal test specifications.

A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

• Sincerely,

~VJ

~

Alan B. Wang, Project Manager Plant Licenl?ing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of N,uclear Reactor Regulation Docket No. 50-458

Enclosures:

1. .Amendment No.J83 to NPF-47

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY GULF STATES LOUISIANA, LLC AND ENTERGY OPERATIONS. INC.

DOCKET NO. 50-458 RIVER BEND STATION. UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 183 License No. NPF-47

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Operations, Inc. (the licensee), dated November 4, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this licens~ amendment will not be inimical to the-common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part- 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-47 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 183 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION Douglas A. Broaddus, Chief Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-47 and Technical Specifications Date of Issuance: -:December 12, 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 183 FACILITY OPERATING LICENSE NO. NPF-47 DOCKET NO. 50-458 Replace the following pages of the Facility Operating License No. NPF-47 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by Amendment number and contain marginal lines indicating the areas of change.

Facility Operating License Remove Technical Specifications Remove Insert 3.6-52 . 3.6-52 3.6-59 3.6-59 3.7-7 3.7-7 5.0-12 5.0-12 5.0-13 5.0-13

(3) EO I, pursuant to the Act and 10 CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) EO I, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; r'

(5) EO I, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) EO I, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3091 megawatts thermal (1 00% rated power) in accordance with the conditions specified herein. The items identified in Attachment 1 to this license shall be completed as specified. Attachment 1 is hereby incorporated into this license. '

• (2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 183 and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 183 I

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for~ 15 continuous 31 days minutes.

SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual . 24 months or simulated initiation signal.

SR 3.6.4.3.4 Verify each SGT filter cooling bypass 24 months damper can be opened and the fan started.

RIVER BEND 3.6-52 Amendment No. S+, 4-S8, 183

Fuel Building Ventilation System-Fuel Handling 3.6.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.7.1 Verify one fuel building ventilation charcoal 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> filtration subsystem in operation.

SR 3.6.4.7.2 Operate each fuel building ventilation charcoal 31 days filtration subsystem for~ 15 continuous minutes.

SR 3.6.4.7.3 Perform fuel building ventilation charcoal filtration In accordance with filter testing in accordance with the Ventilation

• the VFTP Filter Testing Program (VFTP).

SR 3.6.4.7.4 Verify each fuel building ventilation charcoal 24 m6nths filtration subsystem actuates on an actual or simula~ed initiation signal.

SR 3.6.4.7.5 Verify each fuel building ventilation charcoal 24 months filtration filter cooling bypass damper. can be op~ned and the fan started.

RIVER BEND 3.6-59 Amendment No. 31-, +es, 183

CRFA System 3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CRFA subsystems F.1 Suspend movement of Immediately inoperable during recently irradiated fuel movement of recently assemblies in *the primary irradiated fuel assemblies containment and fuel in the primary containment building.

or fuel building, or during OPDRVs.

. F.2 Initiate action to suspend Immediately OPDRVs.

One or more CRFA subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel building, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Operate each CRFA subsystem for::::: 15 continuous 31 days minutes.

SR 3.7.2.2 Perform required CRFA filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.2.3 Verify each CRFA subsystem actuates on an actual 24 months or simulated initiation signal.

(continued)

RIVER BEND 3.7-7 Amendment No. 81 119 132 154 165 168, 183

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass< 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below+/- 10%:

ESF Ventilation System Flowrate SGTS 12,500 cfm FBVS 10,000 cfm CRFAS 4,000 cfm

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and the relative humidity specified below:

ESF Ventilation System Penetration SGTS 5.0% 95%*

FBVS 5.0% 95%

CRFAS 1.0% 95%

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested. in accordance with Regulatory Guide 1.52, Revision 2, and ASME N51 0-1989 at the system flowrate specified below +/- 10%:

ESF Ventilation System Delta P Flowrate SGTS * <8"WG 12,500 cfm FBVS <8"WG 10,000 cfm CRFAS <8"WG 4,000 cfm (continued)

RIVER BEND 5.0-12 Amendment No. B1 115 1a2 165, 183

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

e. Deleted The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the main condenser offgas treatment system and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The program shall include:

a. The limits for concentrations of hydrogen in the main condenser offgas treatment system and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion); and

b. A surveillance program to ensure that the quantity of radioactive material contained in any unprotected outdoor tank is limited to ::;; 10 curies, excluding tritium and dissolved or entrained noble gases.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The (continued)

RIVER BEND 5.0-13 Amendment No. 81 159; 183

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 183 TO FACILITY OPERATING LICENSE NO. NPF-47 ENTERGY OPERATIONS, INC.

RIVER BEND STATION. UNIT 1 DOCKET NO. 50-458

1.0 INTRODUCTION

By letter dated November 4, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13316A005), Entergy Operations Inc. *(Entergy, the licensee),

submitted a license amendment request (LAR) for the River Bend Station, Unit 1 (RBS). In response to a U.S. Nuclear Regulatory Commission (NRC) staff request during a teleconference on May 29, 2014, the licensee provided clarifying information by e-mail dated June 2, 2014 (ADAMS Accession No. ML14155A253). The proposed LAR would revise Technical Specification (TS) Sections 3.6.4.3, "Standby Gas Treatment (SGT) System," 3.6.4.7, "Fuel 1 Building Ventilation System- Fuel Handling," 3.7.2, "Control Room Fresh Air (CRFA) System,"

and 5.5.7, "Ventilation Filter Testing Program (VFTP)."

Specifically, the proposed amendment will eliminate the operability and Surveillance Requirements (SRs) for the heaters in the safety-related charcoal filter trains in those systems, and revise certain charcoal test specifications. The proposed amendment will revise SRs which currently require operating the ventilation system for at least 10 continuous hours every 31 days with the heaters operating to 15 continuous minutes every 31 days. All operability requirements and other references to heaters in the charcoal filter trains in the three systems will be deleted.

TS 5.5.7.c will be revised to change the charcoal test Relative Humidity (RH) conditions from 70 to 95 percent, and to revise the allowable methyl iodide penetration in the Fuel Building Ventilation System (FBVS) from 0.5 to 5 percent.

2.0 REGULATORY EVALUATION

The LAR includes changes to the TS, the contents of which are controlled by requirements in Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.36, "Technical specifications."

TSs are required to include items in the following five categories related to plant operation:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; and (5) administrative controls.

Enclosure 2

The licensee addressed the regulatory requirements applicable to the proposed amendment in Sections 2 and 3 of Attachment 1 to the application dated November 4, 2013. The NRC staff considered the following General Design Criteria (GDC) in Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants," in its review of the proposed amendment:

• GDC 19, "Control room," requires adequate radiation protection be provided to permit access and occupancy or'the control room under accident conditions without personnel receiving radiation exposures in excess of five roentgen equivalent man (rem) whole body, or its equivalent, to any part of the body, for the duration of the accident. The regulations in 10 CFR 50.67, "Accident source term," provides the requirements to licensees who seek to revise the current accident source term (AST) used in the design basis radiological analysis. As part of the implementation of the AST, the total effective dose equivalent (TEDE) acceptance criterion of 10 CFR 50.67 replaces the previous whole body and thyroid guidelines of 10 CFR 100.11, "Determination of exclusion area, low population zone, and population center distance," and GDC 19. By letter dated March 14, 2003 (ADAMS Accession No. ML030760746), the NRC approved Amendment No. 132 to the RBS operability license to implement a full-scale application of AST allowed by 10 CFR 50.67.

• GDC 41, Containment atmosphere cleanup," requires that systems to control fission products released into the reactor containment be provided to reduce the concentration and quality of fission products released to the environment following postulated accidents.

The NRC staff also considered in the safety evaluation (SE) the relevant information contained in the following documents:

• NRC Regulatory Guide (RG) 1.52, Revision 3, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," June 2001 (ADAMS Accession No. ML0117.1 0176).

NRC Generic Letter (GL) 99-02, "Laboratory Testing of Nuclear Grade Activated Charcoal," dated June 3, 2009 (http://www.nrc.gov/reading-rm/doc-collections/gen-com m/gen-letters/1999/g 199002. htm I).

RG 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000 (ADAMS Accession No. ML003716792).

American Society for Testing and Materials (ASTM) Standard D3803-1989, "Standard Tests Method for Nuclear-Grade Activated Carbon," ASTM International, West Conshohocken, PA.

The NRC has approved a significant number of amendment requests to eliminate the operability

• requirements for charcoal filter train heaters and reduce the duration of monthly surveillance tests, similar to the proposed request by Entergy. As precedents to its LAR, the licensee cited

NRC-approved amendments for Prairie Island Nuclear Generating Plant dated July 18, 2008 (ADAMS Accession No. ML081430161), Kewaunee Power Station dated December 30, 2008 (ADAMS Accession No. ML083290653), and Edwin I. Hatch Nuclear Plant dated April 15, 2009 (ADAMS Accession No. ML090340465).

3.0 TECHNICAL EVALUATION

3.1 Background The standby gas treatment (SGT) system is required by 10 CFR 50, Appendix A, GDC 41, "Containment atmosphere cleanup." The function of the SGT system is to ensure that radioactive materials that leak from the primary containment into the secondary containment following a design basis accident (DBA) are filtered and adsorbed prior to exhausting to the environment. The SGT system consists of two fully redundant subsystems, each with its own set of ductwork, dampers, charcoal filter train, and controls .. The design basis for the SGT system is to mitigate the consequences of a loss-of-coolant accident. For all analyzed events, the SGT system is automatically initiated to reduce, via filtration and adsorption, the radioactive material released to the environment.

The FBVS. is required by 10 CFR 50, Appendix A, GDC 41, "Containment atmosphere cleanup."

The function of the FBVS is to ensure that radioactive materials that escape from fuel assemblies damaged following a design basis fuel handling accident are filtered and adsorbed prior to exhausting to the environment. The FBVS consists of two fully redundant subsystems, each with its own set of ductwork, dampers, charcoal filter train, and controls. The design basis for the FBVS is to mitigate the consequences of a fuel handling accident. For all analyzed events, the FBVS is shown to reduce, via filtration and adsorption, the radioactive material released to the environment.

The control room fresh air (CRFA) system provides a protected environment from which the plant operators can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The safety-related function of the CRFA system used to control radiation exposure consists of two independent and redundant high-efficiency air filtration subsystems for treatment of recirculated air or outside supply air, and a control room envelope boundary that limits the inleakage of unfiltered air. The CRFA system is designed to maintain a habitable environment in the control room envelope for a 30-day continuous occupancy after a DBA, per the requirements of GDC 19 and 10 CFR 50.67.

The charcoal filter trains in each ofthe three systems consist of (in order of the direction of the air flow): a moisture separator, an electric heater, a prefilter, a high efficiency particulate air (HEPA) filter, a charcoal adsorber, a second HEPA filter, and a centrifugal fan.

The purpose of the activated charcoal adsorbent is to remove iodine in the form of methyl iodide and elemental iodine. The efficiency of the adsorption process erodes as moisture coats the surface of the charcoal. The electric heater, therefore, serves to enhance carbon efficiency by lowering the RH to less than 70 percent. Analyses of DBAs assume certain carbon adsorption efficiency in the determination of offsite and control room doses. To protect this assumption, testing of the carbon efficiency must demonstrate a higher efficiency than that assumed in accident analysis calculations. As stated in the licensee's letter dated November 4, 2013, RBS

Technical Requirements Manual (TRM) 5.5.7.c specifies the frequency of charcoal adsorbent testing as follows: * -

The testing requirements of Technical Specification 5.5.7.c will be performed at least once per 24 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem; or (3) every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation. The representative carbon sample will be tested within 31 days following removal.

The licensee is not proposing to change the frequency of the. test.

3.2 Proposed Changes to TS Current SR 3.6.4.3.1 states:

Operate each SGT subsystem for~ 10 continuous hours with heaters operating.

Revised SR 3.6.4.3.1 would state:

Operate each SGT subsystem for ~ 15 continuous minutes.

Current SR 3.6.4.7.2 states:

Operate each fuel building ventilation charcoal filtration subsystem for

~ 10 continuous hours with heaters operating.

Revised SR 3.6.4.7.2 would state:

Operate each fuel building ventilation charcoal filtration subsystem for

~ 15 continuous minutes.

Current SR 3.7.2.1 states:

Operate each CRFA subsystem for~ 10 continuous hours with the heaters operating.

Revised SR 3.7.2.1 would state:

Operate each CRFA subsystem for~ 15 continuous minutes.

The surveillance frequency will remain at 31 days.

Current TS Section 5.5.7.c states, in part, that:

ESF Ventilation System Penetration SGTS 5.0% 70%

FBVS 0.5% 70%

CRFAS 1.0% 70%

Revised TS Section 5.5.7.c would state, in part, that:

ESF Ventilation System Penetration SGTS 5.0% 95%

FBVS 5.0% 95%

CRFAS 1.0% 95%

In addition, the license is proposing to delete TS Section 5.5.7.e of the Ventilation Filter Testing Program (VFPT) in its entirety, which currently states:

Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ASME N510-1989:

ESF Ventilation System Wattage SGTS <:: 61 kW FBVS <:: 49 Kw CRFAS <::15kW 3.3 NRC Staff Evaluation 3.3.1 TS Sections 3.6.4.3, 3.6.4.7, and 3.7.2 One of the reasons for the previous 10-hour requirement for ventilation system operation with heaters operating is to minimize the effects of moisture on the adsorber's ability to capture gaseous activity. These requirements are based on the March 1978 NRC staff guidance in RG 1.52, Revision 2, for testing air filtration and adsorption systems (ADAMS Accession No. ML003740139). GL 99-02 was later issued by the NRC, requesting licensees to confirm that their charcoal testing protocols accurately reflect the adsorber gaseous activity capture capability and to account for the effects of moisture accumulation on the adsorbers. The NRC staff subsequently determined in the model SE for Technical Specifications Task Force Traveler TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month" (ADAMS Accession No. ML12158A464) that the 10 continuous hours of heater operation would dry out the charcoal adsorber for a brief period only and that moisture level would return to the pre-test level rather quickly.

RG 1.52, Revision 3, Regulatory Position 6.1 states, "should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the

system and all its components." In addition, RG 1.52, Revision 3 states that plants that test the ventilation system adsorption at a RH of 95 percent do not require heaters for the ventilation system to perform its specified safety function. Therefore, in TSTF-522 the bracketed phrase \

"with heaters operating" is not required in the SRs. At RBS, laboratory testing of the carbon is performed at a RH of 95 percent.

Concurrent with the proposed revision of the surveillance requirements for the operability determination with the heaters on, the licensee is also proposing a change to the VFTP requiring laboratory testing of the charcoal adsorber efficiency from the current requirement for RH of 70 percent to an RH of 95 percent. The licensee stated that deletion of the operability requirements of the heaters will allow the heaters.to be deactivated, gaining significant margin to the design load limits on the Division 1 and 2 Emergency Diesel Generators.

The NRC staff concludes the proposed change to operate SGT, FBVS, and CRFA systems filter trains for 15 minutes is consistent with the position stated in RG 1.52, Revision 3, and is, therefore, acceptable. Since the heaters are no longer required, the proposed deletion of TS Section 5.5. 7.e in its entirety is also acceptable.

3.3.2 TS Section 5.5.7.c Current TS Section 5.5.7.c in the VFTP states:

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and the relative humidity specified below:

ESF Ventilatio~ System Penetration SGTS 5.0% 70%

FBVS 0.5% 70%

CRFAS 1.0% 70%

The licensee is proposing to change the RH from 70 percent to 95 percent for the SGTS, FBVS, and CRFAS, and raise the .FBVS allowable value for methyl iodide penetration during periodic charcoal testing from 0.5 percent to 5.0 percent.

• The TS provides the acceptance criteria for the performance of the SGT and CRFA filters to ensure post-accident consequences remain within the regulatory criteria, and for RBS, these criteria are contained in 10 CFR 50.67, "Accident source term." This regulation provides the criteria for dose limits for individuals located in the exclusion area, low population zone, and to permit access to and occupancy of the control room for licensee who wish to use an alternate source term methodology. To meet these criteria, the licensee has used a method acceptable to the NRC staff that is contained in RG 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors." The licensee was granted approval of the alternate radiological accident analysis in Amendment No. 132 to the RBS

operating licensee. In this analysis, the licensee used a maximum charcoal adsorber filter iodine removal efficiency of 90 percent for the SGT and 98 percent for the CRFA filter trains.

NRC GL 99-02 stated that (1) the laboratory test acceptance criteria contain a safety factor to ensure that the efficiency assumed in the radiological consequence analysis is still valid at the end of the operating cycle, (2) because ASTM D3803-1989, "Standard Test Method for Nuclear-Grade Activated Carbon," is a more accurate and demanding test than older tests, licensees that upgrade their TS to this new protocol will be able to use a safety factor as low as 2 for determining the acceptance criteria for charcoal filter efficiency, and (3) this safety factor can be

• used for systems with or without humidity control because of the lack of humidity control is already accounted for in the test conditions (systems without humidity control can test at 95 percent RH and systems with humidity control can test at 70 percent RH). RBS TS 5.5.7.c.

acceptance criteria for iodine removal efficiency is 90 percent for the SGT and 98 percent for CRFA charcoal filter when tested in accordance with ASTM D3803-1989 at conditions of 30 degrees Celsius (0 C) and 95 percent RH, while the RBS radiological.analyses assumed 90 percent and 98 percent iodine removal for the SGT and CRFA filter trains. Therefore, in regard to RBS, the NRC staff concludes that the licensee has committed to ASTM D3803-1989 and that the penetration and RH acceptance criteria resulted from, and is reflective of, the licensee using a safety factor of 2 in accordance with the guidance provided in GL 99-02, without crediting the heaters. The staff concludes that the offsite and control room dose analyses using the alternative source term as approved in Amendment No. 132 are not affected by the proposed change, and that they will remain within the limits of 10 CFR 50.67. Therefore, the staff concludes that the proposed request to change the RH from 70 percent to 95 percent for the SGT and CRFA filter trains is acceptable.

Amendment No. 113 removed the fuel building from the operability requirements for secondary containment. During a design basis loss-of-coolant accident, all potential leakages to the fuel building are now assumed to be released directly to the environment with no credit for holdup, dilution, or decay by the building or for filtration by the FBVS filters. In addition, Amendment No. 113 also revised the applicability for the fuel building operability during movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). However, RBS has both a licensing requirement and a physical limitation that precludes the loading of recently irradiated fuel in the fuel building. TRM TR 3.9.1 0, "Decay Time,"

requires that the reactor be subcritical for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to movement of irradiated fuel in the reactor vessel. In practicality, cooldown and disassembly of the reactor vessel to the point that fuel handling may begin, takes significantly longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The licensee indicated that the methyl iodine penetration obtained during laboratory tests of charcoal adsorber samples, when converted from the current 70 percent RH to 95 percent RH, leaves very little margin in satisfying the current TS penetration requirement thus increasing the challenge to the operability of charcoal. The proposed change to increase the penetration value to 5 percent diminishes such unnecessary challenges. The selection of 5 percent penetration requirement is based on maintaining consistency with that of the SGTS. The NRC staff concludes that the proposed change to RBS TS 5.5.7.c, concerning the penetration requirement for the FBVS charcoal adsorber penetration test from 0.5 percent to 5 percent is acceptable since, as approved by the NRC in the RBS Amendment No. 113, the FBVS is no longer part of

secondary containment and is no longer credited to mitigate the consequences of any DBA.

The proposed revision to the allowable percent penetration through the FBVS filter carbon bed will have no adverse effects on current operating and accident offsite dose calculations.

The regulation at 10 CFR 50.36 *states, in part, that "A summary statement of the bases or reasons for such specifications ... shall also be included in the application, but shall not become part of the technical specifications." The licensee may make changes to the TS Bases without prior NRC staff review. Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes. The NRC staff determined that TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on TSs Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FR 39132).

This LAR proposes TS changes which reduce the duration of safeguards ventilation system heater testing requirements and change the penetration and RH specifications .for charcoal tests. These changes are consistent with the guidance of RG 1.52, Revision 3, and ASTM D3803-1989 and, therefore, the NRC staff concludes that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on March 4, 2014 (79 FR 12243). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set' forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact stateme*nt or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: . Roberto Torres Date: December 12, 2014

December 12, 2014 Vice President, Operations Entergy Operations, Inc.

River Bend Station 5485 US Highway 61 N St. Francisville, LA 70775

SUBJECT:

RIVER BEND STATION, UNIT 1 -ISSUANCE OF AMENDMENT RE:

• REVISION OF THE VENTILATION FILTER TESTING PROGRAM AND ASSOCIATED SURVEILLANCE REQUIREMENTS (TAC NO. MF3014)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 183 to Facility Operating License No. NPF-47 for the River Bend Station, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 4, 2013.

The amendment revises TS Sections 3.6.4.3, "Standby Gas Treatment (SGT) System," 3.6.4.7, "Fuel Building Ventilation System- Fuel Handling," 3.7.2, "Control Room Fresh Air (CRFA)

System," and 5.5.7, "Ventilation Filter Testing Program (VFTP)." Specifically, the amendment eliminates the operability and Surveillance Requirements for the heaters in the safety-related charcoal filter trains in those systems, and revises certain charcoal test specifications:

A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRA/

Alan B. Wang, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.50-45a

Enclosures:

1. Amendment No. 183 to NPF-47

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorllpl4-2 Resource RidsNrrPMRiverBend Resource LPL4-2 r/f

• RidsNrrDssScvb Resource RidsRgn4MaiiCenter Resource RidsAcrsAcnw_MaiiCTR Resource RidsNrrDssStsb Resource RTorres, NRR/DSS/SCVB .

RidsNrrDoriDpr Resource RidsNrrLAJBurkhardt Resource ADAMS Accession No ML14225A444 OFFICE NRR/DORL/LPL4-2/PM NRR/DORLILPL4-2/LA NRR/DSS/STSB/BC NRR/DSS/SCVB/BC NAME ABWahg JBurkhardt REIIiott RDennig*

DATE 9/9/14 8/15/14 9/10/14 .. 5/29/14 OFFICE OGC NRR/DORLILPL4-2/BC NRR/DORL/LPL4-2/PM NAME SUttal/ NLO DBroaddus ABWang (MOrenak for)

DATE 9/17/14 11/21/14 12/12/14 OFFICIAL AGENCY RECORD