ML15119A226
| ML15119A226 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/23/2015 |
| From: | Olson E Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-08-001, RBG-47557, TSTF-523 | |
| Download: ML15119A226 (13) | |
Text
Entergy0 Entergy Operations, Inc.
River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4374 Eric Olson Site Vice President RBG-47557 April 23, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Reference Response to Request for Additional Information on Application for TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation" River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47 1.) Entergy Letter; Application for Technical Specification Changes Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation" (RBG-47497) Dated September 2, 2014 2.) NRC email; River Bend Station, Unit 1, Request for Additional Information Regarding TSTF - 523 (TAC No. MF4782), Dated March 27, 2015
Dear Sir or Madam:
In Reference 1 Entergy Operations, Inc. (Entergy) submitted a request for an amendment to the Technical Specifications (TS) for River Bend Station (RBS), Unit 1. The proposed amendment modifies the existing Surveillance Requirements (SRs) related to gas accumulation for the Emergency Core Cooling Systems (ECCS). This request was based upon Technical Specification Changes Technical Specification Task Force (TSTF)
Improved Standard Technical Specification Change Traveler, TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation."
In Reference 2 the NRC Staff requested additional information (RAI) in support of this request.
A '3
RBG-47557 Page 2 of 3 provides responses to the RAI with Attachment 2 providing revised TS pages. Attachment 3 includes regulatory commitments to be implemented in support of this change.
If you have any questions or require additional information, please contact Mr. J. A. Clark at (225) 381-4177.
I declare under penalty of perjury that the foregoing is true and correct, executed on April 23, 2015.
Sincerely, EO/JAC/bmb Attachments:
- 1. Response to Request For Information
- 2. Proposed Technical Specification Changes (mark-up)
- 3. List of Regulatory Commitments cc: Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Blvd.
Arlington, TX 76011-4511 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U. S. Nuclear Regulatory Commission Attn: Mr. Alan Wang MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section Ji Young Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312
RBG-47557 Page 3 of 3 Public Utility Commission of Texas Attn: PUC Filing Clerk 1701 N. Congress Avenue P. 0. Box 13326 Austin, TX 78711-3326 RBF1-15-0051 LAR 2014-04 RBG-47557 Response to Request for Information
RBG-47557 Page 1 of 3 By letter dated September 2, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14261A092), Entergy Operations, Inc. (Entergy, the licensee) submitted a license amendment request (LAR) to adopt Technical Specification Task Force Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." The US Nuclear Regulatory Commission (NRC) staff has reviewed the Entergy submittals, regarding changes to adopt TSTF-523 and has determined that the following additional information is required to complete its review of the amendment request:
Requests for Additional Information
- 1. TSTF-523, Revision 2, has been approved by the Commission, and the licensee stated in Attachment 1 of their submittal that the proposed amendment was consistent with TSTF-523, Revision 2. In Attachment 2 of the submittal, Note 2 associated with Surveillance Requirement (SR) 3.5.2.4 refers to "system flow paths" versus the approved TSTF-523 wording, "system vent flow paths...." The "vent" adjective represents verbiage approved in the TSTF.
Please provide a justification for deviating from the approved TSTF-523 wording or resubmit Attachment 2 so that the language is in consistent with the approved TSTF.
Response
The wording was intended to comply with the standard TSTF-523 wording. This is an editorial issue. The revised Technical Specification (TS) markup is included in Attachment 2.
- 2. In Attachment 1 of the submittal two different revisions of TSTF-523 (i.e., Revisions 1 and 2) were referenced. Currently, Revision 2 of TSTF-523 is the approved version, but Revision 1 is referenced on page 3.
Please clarify the revision of TSTF-523 that was adopted and, if necessary, provide justification for the adoption of the previous revision (i.e., Revision 1), which was not approved by the NRC staff.
Response
This is an administrative issue with no change in intent or scope, TSTF-523, Rev. 2, was used for development of the submittal.
- 3. TSTF-523, Revision 2, has been approved by the Commission, and the licensee stated in Attachment 1 of their submittal that the proposed amendment was consistent with TSTF-523, Revision 2. In Attachment 2 of the submittal, SR 3.5.3.1 uses the phrase "sufficiently full with water" versus the approved TSTF verbiage, "sufficiently filled with water." The wording in the submittal is inconsistent with TSTF-523, other similar SRs that were part of the submittal, and the Technical Specification (TS) bases description for this specific SR in Attachment 3 of the submittal.
RBG-47557 Page 2 of 3 Please revise the submittal to be consistent with the approved TSTF-523 language or provide a technical justification for the deviation.
Response
The wording was intended to comply with the standard TSTF-523 wording. This is an editorial issue. The revised TS markup is included in Attachment 2.
- 4. TSTF-523, Revision 2, has been approved by the NRC, and the licensee stated in of their submittal that the proposed amendment was consistent with TSTF-523, Revision 2. In Attachment 2 of the submittal, SR 3.9.9.2 uses the phrase "Verify required RHR shutdown cooling subsystem" versus the approved TSTF verbiage, "Verify RHR shutdown cooling subsystem." The wording in the submittal is inconsistent with TSTF-523 and LCO 3.9.9, which specifies that two trains of RHR shutdown cooling subsystems are required to be OPERABLE.
Please revise the submittal to use language that is consistent with the approved traveler and LCO 3.9.9 or provide a technical justification for the deviation.
Response
The wording was intended to comply with the standard TSTF-523 wording. This is an editorial issue. The revised TS markup included is in Attachment 2.
- 5. The following administrative issues were identified in the TS bases that were submitted in Attachment 3 and are being provided for informational purposes.
i)
The TS bases wording for SR 3.4.9.2 (page 3 of 25) does not correspond to the TS wording in Attachment 2. Specifically, the bases wording states "SR is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> reactor steam dome pressure" versus the TS wording "SR is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure...." Specifically the word "after" is missing from the bases submittal version.
ii)
In Attachment 3 (page 7 of 25), the statement "Management of gas voids is
.important to ECCS injection/spray subsystem OPERABILITY," which was added to the LCO 3.5.1 bases, is grammatically out of place.
iii)
In Attachment 3 (page 6 of 25), a left bracket symbol was mistakenly added to the bases description for SR 3.4.10.2.
RBG-47557 Page 3 of 3
Response
Question 5 identifies editorial issues with the markup of the BASES, no intended change in scope. Entergy will address these items during implementation in accordance with the BASES control program in TS Section 5.5.11.
- 6. As part of the licensee's submittal, two new SRs (i.e., SR 3.4.9.2 and SR 3.4.10.2) were proposed to be implemented after refueling outage 19.
Please provide a justification for delaying the implementation of these SRs relative to the other new SRs that are a part of this submittal.
Response
After further review of the RBS's Gas Management Site Program Document the Shutdown Cooling legs of Residual Heat Removal (RHR) are within its scope and sufficient information is available to determine needed vent locations. As a result additional walk-downs are not required and therefore, the requested delayed implementation of these SRs is not required.
The commitment; For the RHR Shutdown Cooling System, TS 3.4.9 and 3.4.10, the required venting locations will be determined prior to startup from refueling outagqe (RF) 19 currently scheduled for early 2017., is no longer required.
RBG-47557 Proposed Technical Specification Changes (mark-up)
ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for the required High Pressure Core Spray 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (HPCS) System, the:
- a.
Suppression pool water level is >_ 13 ft 3 inches; or
- b.
Condensate storage tank water level is _> 11 ft I inch.
SR 3.5.2.3 Verify, for each required ECCS injection/spray 31 days subsystem, locations susceptible to gas accumulation are sufficiently filled with water. the Pi*ig-*is-"e with water fromn the pump discharge valve to the in~eetiec valve.
NOTE---------------
- 1. One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.
- 2. Not required to be met for system vent flow paths opened under administrative control Verify each required ECCS injection/spray subsystem 31 days manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
(continued)
RIVER BEND 3.5-8 Amendment No. 81
RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System locations susceptible to gas 31 days accumulation are sufficiently filled with water. p4q i s filled with water from the pump diScharge valve to the injection valve.
NOTE -------------------------------
31 days Not required to be met for system vent flow paths opened under administrative control Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
NOTE Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify, with RCIC steam supply pressure < 1075 psig 92 days and > 920 psig, the RCIC pump can develop a flow rate _ 600 gpm against a system head corresponding to reactor pressure.
NOTE Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify, with RCIC steam supply pressure < 165 psig 24 months and > 150 psig, the RCIC pump can develop a flow rate > 600 gpm against a system head corresponding to reactor pressure.
(continued)
RIVER BEND 3.5-11 Amendment No.84-144, 168
RHR - Low Water Level 3.9.9 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B.
(continued)
B.2
,--------NOTE------
Entry and exit is permissible under administrative control.
Initiate action to close Immediately one door in each primary containment air lock.
C.
No RHR shutdown cooling C.1 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery subsystem in operation, circulation by an of no reactor coolant alternate method.
circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND C.2 Monitor reactor coolant Once per hour temperature.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.9.1 Verify one RHR shutdown cooling subsystem is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> operating.
SR 3.9.9.2 Verify RHR shutdown coolingq subsystem 31 days locations susceptible to.qas accumulation are sufficiently filled with water.
RIVER BEND 3.9-13 Amendment No. 81 RBG-47557 List of Regulatory Commitments
RBG-47557 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED COMMITMENT ONE-TIME CONTINUING COMPLETION ACTION COMPLIANCE DATE Entergy will address these items during X
Implementation implementation in accordance with the BASES control program in TS Section 5.5.11.