ML18177A387

Issuance of Amendment No. 192 Addition of New Technical Specification for Control Building Air Conditioning System

ML18177A387
Person / Time
Site:	River Bend
Issue date:	07/31/2018
From:	Lisa Regner Plant Licensing Branch IV
To:	Entergy Operations
Regner, L M, 301-415-1906
References
EPID L-2017-LLA-0291
Download: ML18177A387 (29)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 July 31, 2018 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:

ADDITION OF NEW TECHNICAL SPECIFICATION FOR CONTROL BUILDING AIR CONDITIONING SYSTEM (EPID L-2017-LLA-0291)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 192 to Facility Operating License No. NPF-47 for the River Bend Station, Unit 1 (RBS). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 8, 2017, as supplemented by letter dated March 28, 2018.

The amendment adds a new TS to address the operation of the control building air conditioning (CBAC) system. Specifically, the proposed amendment adds TS 3.7.7, "Control Building Air Conditioning (CBAC) System," to allow greater operational flexibility by adding a new limiting condition for operation, while also ensuring that the CBAC system has the capability to remove the assumed heat load.

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

Docket No. 50-458

Enclosures:

1. Amendment No. 192 to NPF-47

2. Safety Evaluation cc: Listserv Lisa M. Regner, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

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

DOCKET NO. 50-458 RIVER BEND STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 192 License No. NPF-47

1.

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

A.

The application for amendment by Entergy Operations, Inc. (EOI), dated September 8, 2017, as supplemented by letter dated March 28, 2018, 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 license 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.

2.

Accordingly, the license is amended by changes to the Technical Specifications and Appendix C Antitrust Conditions 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. 192 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 90 days from the date of issuance.

Attachment:

Changes to the Facility Operating License No. NPF-47, Technical Specifications, and Appendix C Antitrust Conditions FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: July 31, 2018

ATTACHMENT TO LICENSE AMENDMENT NO. 192 RIVER BEND STATION, UNIT 1 FACILITY OPERATING LICENSE NO. NPF-47 DOCKET NO. 50-458 Replace the following pages of the Facility Operating License No. NPF-47, Appendix A Technical Specifications, and Appendix C Antitrust Conditions 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 V

Insert V

3.7-16 Appendix C Antitrust Conditions Remove Insert (3)

EOI, 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)

EOI, 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; (5)

EOI, 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)

EOI, 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 1 O 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)

(2)

Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3091 megawatts thermal (100% rated power) in accordance with the conditions specified herein. The items identified in Attachment 1 to this license shall be completed as specified. is hereby incorporated into this license.

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 192 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.

Amendment No. 192

TECHNICAL SPECIFICATIONS TABLE OF CONTENTS B 3.6 CONTAINMENT SYSTEMS (continued)

B 3.6.1.5 B 3.6.1.6 B 3.6.1.7 B 3.6.1.8 B 3.6.1.9 B 3.6.1.10 B 3.6.2.1 B 3.6.2.2 B 3.6.2.3 B 3.6.3.1 B 3.6.3.2 B 3.6.3.3 B 3.6.4.1 B 3.6.4.2 B 3.6.4.3 B 3.6.4.4 B 3.6.4.5 B 3.6.4.6 B 3.6.4.7 B 3.6.5.1 B 3.6.5.2 B 3.6.5.3 B 3.6.5.4 B 3.6.5.5 3.7 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 B 3.7 B 3.7.1 B 3.7.2 B 3.7.3 B 3.7.4 B 3.7.5 B 3.7.6 B 3.7.7 Primary Containment Air Temperature.................................................... B 3.6-32 Low-Low Set (LLS)Valves..................................................................... B 3.6-35 Primary Containment Unit Coolers.......................................................... B 3.6-39 DELETED B 3.6-43 Main Steam - Positive Leakage Control System (MS-PLCS)................ B 3.6-47 Primary Containment -Shutdown............................................................ B 3.6-50 Suppression Pool Average Temperature................................................ B 3.6-54 Suppression Pool Water Level................................................................ B 3.6-59 Residual Heat Removal (RHR)Suppression Pool Cooling...................... B 3.6-62 DELETED B 3.6-66 Primary Containment and Drywell Hydrogen lgniters.............................. B 3.6-72 Primary Containment/Drywell Hydrogen Mixing System.......................... 8 3.6-78 Secondary Containment-Operating........................................................ B 3.6-83 Secondary Containment Isolation Dampers (SCIDs)and Fuel Building Isolation Dampers (FBIDs)............................................ B 3.6-89 Standby Gas Treatment (SGT) System................................................... B 3.6-96 DELETED B 3.6-101 Fuel Building B 3.6-104 DELETED B 3.6-107 Fuel Building Ventilation System -Fuel Handling..................................... B 3.6-112 Drywell B 3.6-117 Drywell Air Lock B 3.6-122 Drywell Isolation Valves.......................................................................... B 3.6-129 Drywell Pressure B 3.6-137 Drywell Air Temperature......................................................................... B 3.6-140 PLANT SYSTEMS Standby Service Water (SSW) System and Ultimate Heat Sink (UHS)................................................................................. 3.7-1 Control Room Fresh Air (CRFA)System.................................................... 3.7-5 Control Room Air Conditioning (AC)System.............................................. 3.7-9 Main Condenser Off gas.............................................................................. 3. 7-12 Main Turbine Bypass System..................................................................... 3.7-14 Fuel Pool Water Level................................................................................ 3.7-15 Control Building Air Conditioning (CBAC)System....................................... 3.7-16 PLANT SYSTEMS Standby Service Water (SSW) System and Ultimate Heat Sink (UHS)................................................................................. B 3.7-1 Control Room Fresh Air (CRFA)System.................................................... B 3.7-1 O Control Room Air Conditioning (AC) System.............................................. B 3.7-17 Main Condenser Off gas.............................................................................. B 3.7-22 Main Turbine Bypass System..................................................................... B 3.7-25 Fuel Pool Water Level................................................................................ B 3.7-29 Control Building Air Conditioning (CBAC)System...................................... B 3.7-32

( continued)

RIVER BEND V

Revision No.

Amendment No. 192

Control Building Air Conditioning System 3.7.7

3. 7 PLANT SYSTEMS 3.7.7 Control Building Air Conditioning (CBAC) System LCO 3.7.7 Two Control Building Air Conditioning subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control building air A.1 Restore control building air 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> conditioning subsystem conditioning subsystem to inoperable.

OPERABLE status.

B. Required Action and 8.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not AND met.

8.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Two control building air conditioning subsystems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify each Control Building Air Conditioning subsystem 24 months has the capability to remove the assumed heat load.

RIVER BEND 3.7-16 Amendment No. 192

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 APPENDIX C ANTITRUST CONDITIONS FACILITY OPERATING LICENSE NO. NPF-47 Entergy Louisiana, LLC, is subject to the following antitrust conditions:

( 1)

Definitions (1)(a)

( 1) (b)

(1 )(c)

"Bulk Power" means the electric power, and any attendant energy, supplied or made available at transmission or subtransmission voltage by an entity from its generating facilities.

"Entity" means person, a private or public corporation, governmental agency, an association, a joint stock association, business trust, municipality, or rural electric cooperative owning, operating, or proposing to own or operate equipment facilities for the generation, transmission, or distribution of electricity primarily for sale or resale to the public. Provided, that, except for municipalities, governmental agencies, or rural electric cooperatives, "entity" is further restricted to those which are or will be public utilities under the laws of the State in which the entity transacts or will transact business or under the Federal Power Act, and are or will be providing electric service under a contract or rate schedule on file with and subject to the regulation of a State regulatory commission or the Federal Power Commission.

"Cost" means all operating and maintenance expenses and ownership and capital costs properly allocable to the particular transaction.

"Cost" to be shared by participants under paragraph (9) shall include all costs of acquisition, construction, ownership, capital, operation, and maintenance reasonably allocable to the subject unit. Costs shall include no value for loss of revenues from sale of power at wholesale or retail by one party to a customer which another party might otherwise serve, except as otherwise authorized by any regulatory authority having jurisdiction. Costs shall include a reasonable return on Entergy Louisiana, LLC's investment.

(2)

Entergy Louisiana, LLC shall interconnect with and coordinate reserves by means of the sale and purchase of emergency and/or scheduled maintenance bulk power with any entity(ies) in or within reasonable proximity to Entergy Louisiana, LLC's service area in Louisiana engaging in or proposing to engage in electric bulk power supply on terms that will provide for Entergy Louisiana, LLC's costs in connection therewith and allow the other entity(ies) full access to the benefits and obligations of reserve coordination.

Amendment No. 88, 4-aS, 192 (3)

Such emergency service and/or scheduled maintenance service to be provided by each entity shall be furnished to the fullest extent available from the supplying entity and desired by the entity in need. Entergy Louisiana, LLC and each entity(ies) shall provide to the other such emergency service and/or scheduled maintenance service if and when available from its own generation and from generation of others to the extent it can do so without impairing service to its customers including other electric systems to whom it has firm commitments.

(4)

Entergy Louisiana, LLC and the other entity(ies) which is (are) party(ies) to a reserve sharing arrangement shall from time to time jointly establish the minimum reserves to be installed and/or provided as necessary to maintain in total a reserve margin sufficient to provide adequate reliability of power supply to the interconnected systems of the parties, consistent with good utility industry practice in the region. If Entergy Louisiana, LLC plans its reserve margin on a pooled basis with other regional companies, the reserves jointly established hereunder shall be on the same basis. Unless otherwise agreed upon or established by such regional practice, minimum reserves shall be calculated as a percentage of estimated peak-load responsibility.

No party to the arrangement shall be required to maintain greater reserves than the percentage of its estimated peak-load responsibility which results from the aforesaid calculation; provided that if the reserve requirements of Entergy Louisiana, LLC are increased over the amount Entergy Louisiana, LLC would be required to maintain without such interconnection, then the other party(ies) shall be required to carry or provide for as its (their) reserves the full amount in kilowatts of such increase.

(5)

The entities which are parties to such a reserve sharing agreement shall provide such amounts of ready reserve capacity as may be adequate to avoid the imposition of unreasonable demands on the others in meeting the normal contingencies of operating its system. However, in no circumstances shall the ready reserve requirement exceed the installed reserve requirement.

(6)

Interconnections will not be limited to low voltages when higher voltages are available from Entergy Louisiana, LLC's installed facilities in the area where interconnection is desired, when the proposed arrangement is found to be technically and economically feasible. Control and telemetering facilities shall be provided as required for safe and prudent operation of the interconnected system.

(7)

Interconnection and coordination agreements shall not embody any unlawful or unreasonably restrictive provisions pertaining to intersystem coordination. Good industry practice as developed in the area from time to time (if not unlawfully or unreasonably restrictive) will satisfy this provision.

Amendment No. 88, 458, 192 (8)

Entergy Louisiana, LLC will sell (when available) bulk power at its costs to or purchase (when needed) bulk power from any other entity(ies) in or within reasonable proximity to Entergy Louisiana, LLC's service area in Louisiana engaging in or proposing to engage in generation of electric power at such entity(ies) cost when such transactions would serve to reduce the overall costs of new such bulk power supply, each for itself and for the other party(ies) to the transactions and would serve to coordinate the planning of new generation, transmission, and related facilities by both Entergy Louisiana, LLC and the other entity. This provision shall not be construed to require Entergy Louisiana, LLC to purchase or sell bulk power if it finds such purchase or sale infeasible or its costs in connection with such purchase or sale would exceed its benefits therefrom.

(9)

Entergy Louisiana, LLC and any successor in title, shall offer an opportunity to participate in River Bend Station, Unit 1 for the term of the instant license, or any extensions or renewals thereof, or such term as Entergy Louisiana, LLC and the participant(s) may mutually agree upon, to any entity(ies) in or within reasonable proximity to Entergy Louisiana, LLC's service area in the State of Louisiana which has in writing requested participation therein prior to March 1, 197 4, and which no later than March 31, 1975 has entered into an executory contract with respect to such participation, having taken all necessary action for it to lawfully do so prior to so doing, to a fair and reasonable extent and on reasonable terms and conditions and on a basis that fully compensate Entergy Louisiana, LLC for its costs incurred and to be incurred and that will not adversely affect the financing and constructing of this nuclear unit. Entergy Louisiana, LLC shall similarly offer an opportunity to participate in any additional nuclear generating unit(s) the power from which is intended for use in Entergy Louisiana, LLC's general system operations, which Entergy Louisiana, LLC may construct, own, and operate in Louisiana during the terms of the instant license(s), or any extension(s) or renewal(s), thereof.

Participation shall be either by ownership of or purchase of unit participation power from the respective nuclear units. Participation in any form shall be on an equitable basis whereby the participants, in proportion to their interests, share fully in all costs and risks of the respective nuclear units. In connection with such participation, Entergy Louisiana, LLC will offer transmission service as may be required for delivery of such power to such participants(s) on a basis that will fully compensate Entergy Louisiana, LLC for its costs.

(10)

Entergy Louisiana, LLC shall facilitate the exchange of bulk power by transmission over its transmission facilities between two or more entities engaging in bulk power supply in its service area in Louisiana with which it is interconnected; and between any such entity(ies) and any entity(ies) engaging in bulk power supply outside Entergy Louisiana, LLC's service area in Louisiana between whose facilities Entergy Louisiana, LLC's transmission lines and other transmission lines would form Amendment No. 88, 4-§8, 192 a continuous electrical path; provided that (i) permission to utilize such other transmission lines has been obtained by the entities involved; (ii) Entergy Louisiana, LLC has appropriate agreements for transmission service with the entities interconnected with Entergy Louisiana, LLC at both the receiving and delivery points on Entergy Louisiana, LLC's system; and (iii) the arrangements reasonably can be accommodated from a functional and technical standpoint. Such transmission shall be on terms that fully compensate Entergy Louisiana, LLC for its cost. Any entity(ies) requesting such transmission arrangements shall give reasonable advance notice of its (their) schedule and requirements. (The foregoing applies to any entity(ies) engaging in bulk power supply to which Entergy Louisiana, LLC may be interconnected in the future as wellas those to which it is now interconnected.)

(11)

Entergy Louisiana, LLC shall include in its planning and construction program sufficient transmission capacity as required for the transactions referred to in paragraph (10); provided, that any entity(ies) in its service area in Louisiana gives Entergy Louisiana, LLC sufficient advance notice as may be necessary to accommodate its (their) requirements from a functional and technical standpoint and that such entity(ies) fully compensate Entergy Louisiana, LLC for its cost.

Entergy Louisiana, LLC shall not be required to construct transmission facilities which will be of no demonstrable present or future benefit to Entergy Louisiana, LLC.

(12)

Entergy Louisiana, LLC will sell power (when available) for resale to any entity(ies) in its service area in Louisiana now engaging in or proposing in good faith to engage in retail distribution of electric power, whenever power to meet the needs of such entity(ies) is not available form alternate sources at competitive costs.

(13)

The foregoing conditions shall be in all respects implemented on reasonable terms and conditions in a manner consistent with the provisions of the Federal Power Act and other applicable Federal and State laws and regulatory orders, and shall be subject to force majeure, applicable curtailment programs, and engineering and technical feasibility for Entergy Louisiana, LLC's system. None of the foregoing conditions shall require Entergy Louisiana, LLC to sell power, perform any service, or engage in any course of action on a basis which would be unlawfully preferential or discriminatory under any applicable law or that would impair Entergy Louisiana, LLC's ability to render adequate and reliable service to its own customers. All rates, charges or practices in connection therewith are to be subject to the approval of regulatory agencies having jurisdiction over them.

Amendment No. 88, 408, 192

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 192 TO FACILITY OPERATING LICENSE NO. NPF-47 ENTERGY OPERATIONS, INC.

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

1.0 INTRODUCTION

By application dated September 8, 2017 (Reference 1 ), as supplemented by letter dated March 28, 2018 (Reference 2), Entergy Operations, Inc. (Entergy, the licensee) requested the addition of a new Technical Specification (TS} to the River Bend Station, Unit 1 (RBS) facility operating license.

The license amendment request (LAR) proposed a new TS to address the operation of the RBS control building air conditioning system (CBAC). Specifically, the proposed amendment would add TS 3.7.7, "Control Building Air Conditioning (CBAC) System," including (1) a Limiting Condition for Operation (LCO) statement, (2) an Applicability statement, during which the LCO must be met, (3) Actions to be applied when the LCO is not met, including Conditions, Required Actions, and Completion Times, and (4) Surveillance Requirements (SRs) with a specified Frequency to demonstrate that the LCO is met.

The licensee also requested to correct administrative errors that were inadvertently introduced during an application for an Order to approve license transfers and conforming amendments by letter dated June 10, 2014 (Reference 3), as supplemented by letters dated October 9, 2014, December 31, 2014, and January 30, 2015 (References 4, 5, and 6, respectively)

The supplemental letter dated March 28, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC, the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on January 30, 2018 (83 FR 4291 ).

2.0 REGULATORY EVALUATION

2.1

System Description

In the submittals (References 1 and 2), the licensee described the systems that provide cooling, heating, and ventilation for the control building, including heat rejection pathways via the chilled water system to the service water system. The licensee summarized these systems as follows:

Control Building HVAC [Heating, Ventilation, and Air Conditioning] System (HVC)

The HVC system is designed to provide cooling, heating, and ventilation, for the main control room, standby switchgear rooms, standby 125 Vdc [Volts-direct current] battery rooms, battery charger rooms (standby DC [direct current]

equipment rooms), cable vaults/chases, chiller equipment rooms and general areas of the control building. The HVC system also provides pressurization for the main control room. The HVC system is supported by the Control Building Chilled Water System (HVK).

The HVC system consists of two redundant subsystems that provide cooling and heating of the control building air via the following 100 percent capacity AC [air conditioning] units [ACUs].

HVC-ACU1A/B: Main Control Room AC units serve the main control rooms via common ductwork....

HVC-ACU2A/B: Standby Switchgear Room AC units serve the standby switchgear rooms, standby 125Vdc battery rooms, DC equipment rooms, cable vaults/chases, and general areas of the control building via common ductwork.

HVC-ACU3A/B: Chiller Equipment Room AC units serve the chillers.

The HVC system is designed to operate during normal, shutdown, loss of offsite power, and design-basis accident (DBA) conditions without a loss of function....

Control Building Chilled Water System (HVK)

The HVK system is designed to remove heat generated within the control building to maintain the required environmental conditions. This system supports the HVC system by supplying the cooling source for the HVC AC units. The HVK system consists of two redundant subsystems that provide closed loop chilled water. Each subsystem contains two chillers, either one of which is capable of meeting the total chilled water demand of HVC. Each subsystem of HVK contains two 100-percent capacity electric motor-driven, centrifugal liquid chillers (HVK-CHL 1A/B/C/D), two 100-percent capacity chilled water recirculation pumps (HVK-P1A/B/C/D), and one chilled water compression tank (HVK-TK1A/B), and is supported by two 100-percent capacity chiller recirculation pumps (SWP-P3A/B/C/D) in the Service Water system. Normally only one HVK subsystem is operating. Within that operating subsystem, only one chiller [and one chilled water pump] is operating. The non-operating subsystem has one chiller [and one chilled water pump] in standby.

The HVK system supplies chilled water during normal, shutdown, and DBA conditions to the HVC system consisting of the main control room air conditioning units, the standby switchgear room air conditioning units, and the chiller equipment room air conditioning units. Each HVK subsystem has separate connections to the corresponding service water subsystem. During normal operation, water to the chiller condenser cooling circuits is supplied from the Normal Service Water (NSW) system. During a loss of offsite power or loss of NSW, the water is supplied from the Standby Service Water (SSW) system. The SSW system is also connected to the chilled water circuit. In the event both chilled water trains fail, partial cooling can be achieved by using the SSW system instead of the chilled water as described in USAR [Updated Safety Analysis Report] Section 9.2.10.3.

As discussed in the USAR [S]ection 9.2.10, the HVK system provides a reliable source of cooling water for the chilled water coils of air conditioning units (HVC) located in the control building. The system is designed to operate during normal, shutdown, or accident conditions without loss of function. [Specifically, the heat generated in the control building includes all normal operating room heat loads in all applicable Modes (1, 2, & 3). Accident room heat loads are for a Loss of Coolant Accident (LOCA) without a Loss of Offsite Power (LOP). The heat generated does not include normal equipment that trips under accident conditions.] The HVK system is designed to [Safety Class 3,] Seismic Category I criteria and is connected to the standby [AC] power supplies. All equipment is located in the control building which is a tornado proof, Seismic Category I structure.

Normal Service Water (NSW) [and] Standby Service Water (SSW)

NSW provides cooling water to various systems including HVK during all modes of plant operation. NSW operates during normal plant operation. Upon complete loss of NSW or in emergency conditions, cooling water for HVK is provided by the SSW. The safety-related standby service water system operates in conjunction with the ultimate heat sink, to remove heat from those plant components required for the safe shutdown and cooldown of the unit. Each division is capable of providing sufficient cooling water to one of four HVK chillers for minimum conditions which are essential to the safe shutdown of the reactor.

If one SSW subsystem is inoperable, cooling to both chillers in the associated HVK subsystem (HVK-CHL 1 A and HVK-CHL 1 C or HVK-CHL 1 B and HVK-CHL 1 D) would be unavailable. This will result in the loss of the ACUs in the associated HVC subsystem (HVC-ACU1A, HVC-ACU2A, and HVC-ACU3A or HVC-ACU1 B, HVC-ACU2B, and HVC-ACU3B). The non-affected HVK and HVC subsystems will still be operable and capable of providing 100% cooling. This scenario has the same results as taking one subsystem of the CBAC system out of service, in addition to the many functions impacted by having one SSW subsystem inoperable.

Per TS 3.7.1 Condition G, in modes 1, 2, and 3, the SSW System is required to be operable to support operability of the equipment serviced by the SSW System required to be operable in these modes. If one SSW subsystem is inoperable, it must be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (TS 3. 7.1 Condition G, Required Action G.1 ). With the unit in this condition, the remaining operable SSW subsystem is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the operable SSW subsystem could result in loss of SSW function.

Additional information for the NSW and SSW systems is located in the RBS USAR Section 9.2.1, "Normal Service WaterSystem," and Section 9.2.7, "Standby Service Water System," respectively.

The licensee stated that the proposed new TS LCO 72-hour completion time (CT) was developed considering the redundant capabilities afforded by the operable subsystem and the low probability of a DBA occurring during this period. Since the loss of one SSW subsystem has the same result as losing one subsystem of CBAC in addition to the other consequences of losing one SSW subsystem, loss of one subsystem of CBAC is bounded by TS 3.7.1 Condition G, Required Action G.1.

2.2 Purpose of the Proposed New Technical Specification In 2016, the NRC documented the results of a special inspection at RBS concerning the loss of control building ventilation (Reference 7). The violation involved the licensee's failure to adequately assess the increase in risk of operating the control building chilled water system chillers in various single-failure vulnerable configurations. The NRC determined that the licensee had incorrectly applied an exception provided in the TS LCO 3.0.2 and allowed by LCO 3.0.61 (References 8 and 9).

Currently, the safety-related main control room AC system is addressed by TS 3.7.3, "Control Room Air Conditioning (AC) System." This TS requires two control room air conditioning subsystems to be operable. When one required air conditioning subsystem becomes inoperable, TS 3.7.3, Required Action A.1, requires restoration of the inoperable air conditioning subsystem to operable status within 30 days. However, the remaining portions of the CBAC systems (HVC-ACU2A/B and HVC-ACU3/A) are not currently addressed by the TSs.

In the event that one subsystem of HVK chilled water becomes non-functional, the licensee must consider the supported divisional equipment in the switchgear rooms, battery rooms, etc.,

non-functional as well. The most limiting TS is TS 3.8.4, "DC Sources-Operating," with a CT of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, otherwise the plant must shutdown within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of one required battery charger on Division I or II being inoperable. Other restrictive CTs are 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the invertors in TS 3.8. 7, "Inverters-Operating," and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the distribution systems in TS 3.8.9, "Distribution Systems-Operating," with similar 12-hour Mode 3 shutdown requirements. The licensee cannot apply the exception provided in LCO 3.0.2 allowed by LCO 3.0.6 since the subsystems (i.e., HVK and CBAC) are not addressed in the TSs.

To mitigate the challenge imposed by the short required action completion times, the licensee proposed to include the CBAC system as a supporting system with a corresponding LCO. The proposed change would allow the licensee additional operational flexibility allowed by applying 1 LCO 3.0.6 states, in part, that "[w]hen a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system."

the exception to LCO 3.0.2 allowed by LCO 3.0.6 (i.e., when one subsystem of the CBAC system is inoperable). This is further described in the next section of the safety evaluation (SE).

2.3 Proposed New TS 3.7.7 In the application, as amended (References 1 and 2), the licensee proposed new TS 3.7.7 and defined the CBAC system as the HVC and the HVK equipment that supports standby switchgear rooms, standby 125 Vdc battery rooms, DC equipment rooms, cable vaults and chases, chiller equipment rooms, and general areas of the control building. The proposed TS, including the LCO, Applicability, and the associated SR, is shown below.

3. 7 PLANT SYSTEMS 3.7.7 Control Building Air Conditioning (CBAC) System LCO 3.7.7 Two Control Building Air Conditioning subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION A. One control building air A.1 Restore control building air conditioning subsystem conditioning subsystem to inoperable.

OPERABLE status.

B. Required Action and B.1 Be in MODE 3.

associated Completion Time of Condition A not AND met.

B.2 Be in MODE 4.

OR Two control building air conditioning subsystems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3. 7. 7.1 Verify each Control Building Air Conditioning subsystem has the capability to remove the assumed heat load.

COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 12 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> FREQUENCY 24 months In addition, to reflect the addition of new TS 3.7.7, a change was proposed to the Table of Contents.

2.4 Applicable Regulatory Requirements and Guidance The NRC staff identified the following regulatory requirements and guidance applicable to the proposed amendment to add new TS 3.7.7. The LAR also proposes to add an associated LCO 3.7.7 and SR 3.7.7.1.

2.4.1 Regulatory Requirements and General Design Criteria Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.36(a)(1) requires an applicant for an operating license to include proposed TSs in the application in accordance with the requirements of 10 CFR 50.36.

As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per the regulation, 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation, 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items meeting one or more of the following criteria.

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(D) Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The regulation, 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

As stated in the RBS USAR, Section 3.1, "Conformance with NRC General Design Criteria," the design criteria for safety-related plant structures, systems, and components is in accordance with 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," referred to as GDC.

The HVC ACUs addressed by the proposed new TS are designed to Safety Class 3, Seismic Category I criteria (refer to RBS USAR, Section 9.4.1, "Control Building Ventilation System")

and are connected to the standby alternating current power supplies. All equipment is located in the control building, which is a tornado proof, Seismic Category I structure. Section 3.2.2.1.3, "Safety Class 3," of the RBS USAR states that "Safety Class 3 applies to those structures, systems, and components that are not Safety Class 1 or 2, but which provide or support safety system functions." No modifications to the design or operation of the HVC units are being proposed in the LAR. The LAR proposes to add the equipment to the RBS TSs.

Section 3.1 of the RBS USAR states that RBS conforms to the following GDCs. The NRC staff evaluated whether these GDC continue to be met during its review of the LAR:

Design Basis for Protection against Natural Phenomena (GDC 2)

Environmental and Missile Design Bases (GDC 4)

Electric Power Systems (GDC 17)

Inspection and Testing of Electrical Power Systems (GDC 18)

Cooling Water (GDC 44)

Inspection of Cooling Water System (GDC 45)

Testing of Cooling Water System (GDC 46) 2.4.2 Regulatory Guidance NUREG-1434, Revision 4 (References 10 and 11 ), contains the Standard TSs (STSs) for General Electric Boiling Water Reactor (BWR)/6 plants, and is part of the regulatory standardization effort. The NRC staff prepared STSs for each of the light-water reactor (LWR) nuclear designs.

The NRC staffs guidance for the review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition" (Reference 12).

2.5 Proposed Change to Facility Operating License, Appendix C "Antitrust Conditions" The licensee requested to correct errors in the Facility Operating License No. NPF-47 for RBS, Appendix C "Antitrust Conditions" that were inadvertently introduced by Order and conforming amendment related to the transfer of the license in August and October 2015 (References 13 and 14, respectively). The licensee proposed to correct the licensee name in Appendix C of the RBS Facility Operating License from Entergy Gulf States Louisiana, LLC, to Entergy Louisiana, LLC, since the licensee was previously approved for this transfer. The NRC staff's review of this request is discussed in Section 3.6, "Administrative Correction," of this SE.

3.0 TECHNICAL EVALUATION

3.1 NRC Staff Assessment of CBAC System Qualification The CBAC system consists of two independent redundant subsystems that provide cooling and heating of the control building air. Each subsystem consists of two AC units, each able to provide 100 percent capacity to its designated areas. One AC unit (HVC-ACU2A or 28) serves the standby switchgear rooms, standby 125 Vdc battery rooms, DC equipment rooms, cable vaults, and general areas of the control building. The other AC unit (HVC-ACU3A or 38) serves the chiller equipment rooms. The associated control building chilled water subsystem supplies chilled water to both of the subsystem AC units as well as to the main control room AC units (HVC-ACU1A or 1 B). Since the main control room AC units are governed by TS 3.7.3, these are not included in the proposed new TS 3.7.7.

The HVC system is designed to operate during normal, shutdown, LOP, and DBA conditions without a loss of function. In the letter dated March 28, 2018 (Reference 2), the licensee stated that during normal operations, one division is always running with one division in standby, as opposed to only running the divisions during an event or testing. Specifically, Division A is composed of HVC-ACU1A, HVC-ACU2A, and HVC-ACU3A, and Division Bis composed of HVC-ACU1 B, HVC-ACU2B, and HVC-ACU3B. Table 3-1, "Summary of CBAC Subsystems," in this SE further describes these divisions.

In the letter dated March 28, 2018, the licensee stated, in part:

Every time a divisional swap occurs, the system is effectively tested. If a low flow of air were to occur or loss of chilled water ( chiller), the division would automatically swap to the standby division. Division swaps occur as needed throughout the year.

System alignment is controlled by [station procedures] and dampers automatically align with the automatic start of the division. Manual dampers for ACUs are used as balancing dampers and are not normally manipulated except to rebalance the air flows or equipment Lock-outs.

The HVC ACUs noted above are designed to Safety Class 3, Seismic Category I criteria (USAR Section 9.4.1) and are connected to the standby alternating current power supplies. All equipment is located in the control building which is a tornado proof, Seismic Category I structure. RBS USAR Section 3.2.2.1.3, "Safety Class 3," states, in part, that "Safety Class 3 applies to those structures, systems, and components that are not Safety Class 1 or 2, but which provide or support safety system functions." No modifications to the design or operation of the HVC is being proposed in the LAR.

When one required subsystem is inoperable, the proposed Required Action A.1 is to restore the required CBAC subsystem to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The proposed TS 3. 7. 7 CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will allow time for the licensee to complete minor maintenance activities on the associated equipment and thus reduce the need for an unnecessary plant shutdown. With the unit in this condition, the remaining operable subsystem of CBAC is adequate to perform the control building air conditioning function.

During power operation, startup, and hot shutdown (TS Modes 1, 2, and 3), two independent and redundant subsystems of the CBAC are required to be operable to ensure that at least one is available, assuming a single failure disables the other subsystem. If both subsystems of the CBAC system are inoperable, the system may not be capable of performing its intended function; therefore, a shutdown is required. This action is consistent with the requirements on the supported systems.

During cold shutdown and refueling (TS Modes 4 and 5), there is no specific TS addressing the CBAC system. The operability of the supported systems is addressed in their individual TSs.

This maintains the current CBAC licensing basis. The CBAC is considered operable when the individual components necessary to maintain the control building rooms and areas are operable.

These components include the cooling coils, fans, chillers, compressors, ductwork, dampers, and associated instrumentation and controls.

Section 50.36 of 10 CFR requires a TS LCO for a n!Jclear reactor to be established for each item meeting one or more of the documented criteria. Criterion 3 includes structures, systems, or components that are part of the primary success path and which function or actuate to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The NRC staff determines that the CBAC system meets Criterion 3 of 10 CFR 50.36 since it provides essential cooling to components important to safety such as alternating current electrical buses, direct current batteries, and chiller equipment.

In the LAR (Reference 1), the licensee proposed SR 3.7.7.1 as:

Verify the control building AC system has the capability to remove the assumed heat load.

In the supplemental letter (Reference 2), the licensee clarified information related to proposed SR 3.7.7.1 and changed the proposed SR 3.7.7.1 to require verification of each air conditioning subsystem's heat removal capability every 24 months. Specifically, the licensee modified proposed SR 3.7.7.1 to state:

Verify each Control Building Air Conditioning subsystem has the capability to remove the assumed heat load.

Also, in the supplemental letter, the licensee further stated that "[t]he current Surveillance Test Procedure (STP) STP-410-3601/2/3/4 'Performance Monitoring Program for Control Building Chiller HVK-CHL 1A/B/C/D' tests the heat removal capability of the chillers." The licensee clarified that this STP currently satisfies SR 3.7.3.1 for the Control Room Air Conditioning System. The licensee added that a statement similar to the following will be added to the corresponding CBAC procedure.

This procedure verifies that the Control Building Air Conditioning has the capability to remove the assumed heat load. The purpose of this procedure is to provide instructions and test the A/B/C/D train of the Control Building Air Conditioning subsystem through HVK-CHL 1A/B/C/D. This test partially implements the requirements of Technical Specification SR 3.7.7.1.

In the supplemental letter, the licensee also provided the following clarification regarding surveillance testing of HVC ACUs:

A new STP will be created to flow test HVC-ACU2A/B Control Building Air Handling Unit-2A/B. The purpose of this procedure will be to provide instructions for collecting test data necessary to satisfy a portion of SR 3. 7. 7.1. The new STP will be modeled after the current STP-402-4203/4 "HVC-ACU1A/B Performance Monitoring" for HVC-ACU1A/B Control Room Air Handling Unit 1 A/B.

A new STP will be created to flow test HVC-ACU3A/B Chiller Equipment Room Air Handling Unit 3A/B. The purpose of this procedure will be to provide instructions for collecting test data necessary to satisfy a portion of SR 3. 7. 7.1.

The new STP will be modeled after the current STP-403-0301/3 "Containment Unit Cooler HVR-UC1A/B Flow Rate Verification."

Based on the information contained in the submittals (References 1 and 2) and the USAR, the NRC staff concludes that the CBAC system is fully qualified to be included in the RBS TSs.

Specifically, the CBAC system provides temperature control for the standby switchgear rooms, standby 125 Vdc battery rooms, DC equipment rooms, cable vaults, chiller equipment rooms, and general areas of the control building. The CBAC system consists of two independent redundant subsystems (Seismic Category I, Safety Class 3) that provide cooling and heating of the control building air. Each subsystem consists of two AC units, each 100 percent capacity units to serve their designated areas.

3.2 NRC Staff Evaluation of Proposed TS 3.7.7 One AC unit (standby switchgear room AC unit) (HVC-ACU2A or 28) serves the standby switchgear rooms, standby 125 Vdc battery rooms, DC equipment rooms, cable vaults, and general areas of the control building. The other AC unit (chiller equipment room AC unit)

(HVC-ACU3A or 38) serves the chiller equipment rooms. The associated control building chilled water subsystem supplies chilled water to both of the subsystem AC units, as well as to the main control room AC units (governed by separate TS 3.7.3).

The standby switchgear room AC unit consists of a fan, filter, chilled water coil, and electric heating coils. The chiller equipment room AC unit consists of an outside air supply, room exhaust, and chilled water coils. An electric heating coil is provided to maintain minimum supply air temperature.

To clarify the RBS design of the CBAC system with supporting equipment and to emphasize the relation to the CBAC subsystem divisions with component interconnections directly related to the LAR, the following SE Table 3-1 was generated.

Table 3-1 Summary of CBAC Subsystems Division 1 Subsystem Division 2 Subsystem HVC-Standby Switchgear Room AC unit HVC-Standby Switchgear Room AC unit ACU2A (rated at 29,330 cubic feet per minute ACU2B (rated at 29,330 cfm)

(cfm))

Status:

Status:

This AC unit is capable of cooling both This AC unit is capable of cooling both divisional rooms simultaneously, utilizing

• divisional rooms simultaneously, utilizing shared HVAC ducts, and is not currently shared HVAC ducts, and is not currently in in the TSs, but the LAR proposed to add the TSs, but the LAR proposed to add new new TS 3.7.7.

TS 3.7.7.

HVC-Chiller Equipment Room AC unit HVC-Chiller Equipment Room AC unit ACU3A (rated at 3,500 cfm)

ACU3B (rated at 3,500 cfm)

Status:

Status:

Not currently in the TSs, but the LAR Not currently in TSs, but the LAR proposed to add new TS 3.7.7.

proposed to add new TS 3.7.7.

HVK-Centrifugal liquid chillers (2 units, each HVK-Centrifugal liquid chillers (2 units, each CHL1A 100 percent capacity)

CHL1B 100 percent capacity) and HVK-and HVK-CHL1C Status:

CHL1D Status:

Control Room is common to Divisions 1 Control Room is common to Divisions 1 and 2. Each chiller is capable of cooling and 2. Each chiller is capable of cooling the Control Room AC unit, both Division 1 the Control Room AC unit, both and Division 2 Standby Switchgear Room Division 1 and Division 2 Standby AC units, and 'A' Chiller Equipment Room Switchgear Room AC units, and 'B' AC unit.

Chiller Equipment Room AC unit.

HVK-P1A Chilled water recirculation pumps HVK-P1B Chilled water recirculation pumps and HVK-(2 units, each 100 percent capacity) and HVK-(2 units, each 100 percent capacity)

P1C P1D Status:

Status:

Each pump is capable of providing chilled Each pump is capable of providing water flow to one of the two Division 1 chilled water flow to one of the two chillers.

Division 2 chillers.

SWP-P2A SSW System Pumps for the Ultimate Heat SWP-P2B SSW System Pumps for the UHS and SWP-Sink (UHS) cooling tower and SWP-cooling tower P2C*

P2D

• Note: SWP-P2C is powered by Division 3 Emergency Power but located on the Division 1 SWP piping supply header Status:

Status:

Each of the 2 pumps for the Division 1 Each of the 2 pumps for the Division 2 SSW header are capable of providing SSW header are capable of providing 50 percent flow. The SSW system is used 50 percent flow. The SSW system is in emergency conditions or loss of NSW.

used in emergency conditions or loss of SSW and UHS are addressed under NSW. SSW and UHS are addressed TS 3. 7.1 and no changes are proposed by under TS 3.7.1 and no changes are the LAR.

proposed by the LAR.

Normal Service Water (normal operations and isolates during emergencies)- comprised of 3 pumps, each with 50 percent capacity 3.3 NRC Staff Evaluation of Proposed Limiting Condition for Operation, Actions, and Completion Times The LAR requested a new TS to address the operation of the CBAC system.

LCO 3.7.7 would state:

Two Control Building Air Conditioning subsystems shall be operable.

LCO 3.7.7 APPLICABILITY would be for MODES 1, 2, and 3.

As previously described in Section 2.1 of this SE, the CBAC system consists of two independent redundant subsystems that provides cooling and heating of the control building air. Each subsystem consists of two AC units, each with 100 percent capacity to serve its designated areas. For the proposed TS:

HVC-ACU2A/B: Standby Switchgear Room AC units serve the standby switchgear rooms, standby 125Vdc battery rooms, DC equipment rooms, cable vaults/chases, and general areas of the control building via common ductwork. The standby switchgear room AC unit consists of a fan, filter, chilled water coil, and electric heating coils.

HVC-ACU3A/B: Chiller Equipment Room AC units serve the chillers. The chiller equipment room AC unit consists of an outside air supply, room exhaust, and chilled water coils. An electric heating coil is provided to maintain minimum supply air temperature.

The associated control building chilled water subsystem supplies chilled water to both of the subsystem AC units, as well as to the main control room AC units (governed by separate TS 3.7.3). The CBAC system is designed to operate during normal, shutdown, loss of offsite power, and OBA conditions without a loss of function.

In Modes 1, 2, or 3, the CBAC system must be operable to ensure that the control building temperature will not exceed equipment operability limits. In Modes 4 and 5, this proposed new TS is no longer applicable. The following supported systems TSs will be applicable.

River Bend TS 3.8.4 DC Sources-a 3.8.7 3.8.9 The proposed Condition A ACTION would state that if one CBAC subsystem is inoperable, the subsystem is to be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Proposed Condition B ACTION would state that if the required Condition A is not met or if two CBAC subsystems are inoperable, the unit must enter Mode 3 (Hot Shutdown and greater than 200 degrees Fahrenheit primary temperature) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 (Cold Shutdown and less than or equal to 200 degrees Fahrenheit primary temperature) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The NRC staff reviewed the proposed TS LCO 3.7.7 and Actions and finds them acceptable based on the actions to be taken to mitigate a loss of one train of the CBAC subsystem or two trains of the CBAC subsystem. Specifically, with the unit in Modes 1, 2, or 3, TS 3.7.7 Condition A specifies that as long as the remaining operable CBAC subsystem is adequate to perform the control building air conditioning function and maintain required safety functions, the unit can continue to operate to recover the subsystem for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In addition, the HVK system provides a reliable source of cooling water for the chilled water coils of HVC located in the control building.

The system is designed to operate during normal, shutdown, or accident conditions without loss of function. During a LOCA, with LOP, one 100-percent chiller is capable of removing the heat load generated in the control building. The HVK system is designed to Seismic Category I, Safety Class 3, criteria and is connected to the standby alternating current power supplies.

However, the overall reliability is reduced because a single failure in the operable subsystem could result in loss of the control building air conditioning function. The NRC staff finds this acceptable because the 72-hour CT for Required Action A is based on the existing TS 3.7.1 required actions for SSW and UHS, on the low probability of an event occurring that results in a loss of all cooling to the building, the fact that the remaining subsystem can provide the required function, and the availability of alternate cooling methods.

With the unit in TS 3.7.7 Required Action B, if the inoperable CBAC subsystem cannot be restored to operable status within the associated CT or if both CBAC subsystems are inoperable, the CBAC system may not be capable of performing its intended function and the unit must be placed in a mode that minimizes risk. To achieve this, the unit must be shutdown and placed in at least Mode 3 (Hot Shutdown) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and Mode 4 (Cold Shutdown) in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Referring to Table 3-1 in this SE, the centrifugal liquid chillers (HVK-CHL 1A, 1 B, 1 C, and 1 D) and chilled water recirculation pumps (HVK-P1A, P1B, P1C, and P1D) are supporting equipment for the operability of the Control Room Air Conditioning System in existing TS 3.7.3.

The CT for restoration of one inoperable AC subsystem to operable status in TS 3.7.3, Required Action A.1 is 30 days. The chillers and chilled water recirculation pumps will also support operability of the Standby Switchgear Room AC Units and Chiller Equipment Room AC Units based on the proposed addition of TS 3.7.7, with a 72-hour CT for restoration of an inoperable control building AC subsystem to operable status. Compared to the 30-day CT in TS 3.7.3, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is a reduced CT. The NRC staff notes that the higher redundancy in the design of the chilled water system with four 100 percent capacity chillers and four 100 percent capacity chilled water pumps (i.e., two 100 percent capacity chillers and two 100 percent capacity pumps in each division) will provide flexibility in managing the CT in TS 3.7.7.

Based on the above discussion, the NRC staff has evaluated the proposed new TS and determined that the proposed requirements are less restrictive than the licensee's current requirements; however, the staff finds that the LCO correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility as required by 10 CFR 50.36, Criterion 3. For this proposed TS, when an LCO is not met, the licensee shall either shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The NRC staff concludes that the required actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public.

3.4 Staff Evaluation of Proposed TS Surveillance Requirement 3.7.7.1 The requested change to the TSs would add a new TS SR to address the operation of the CBAC system.

The proposed TS SR 3.3. 7.1 includes the verification of each CBAC subsystems' capability to remove the assumed heat load. This SR verifies that the heat removal capability of the subsystem is sufficient to remove the control building heat load assumed in the safety analysis.

Specifically, the capability of each CBAC subsystem includes both trains of the standby switchgear rooms, standby 125Vdc battery rooms, battery charger rooms (standby DC equipment rooms), cable vaults/chases, and general areas of the control building. The SR consists of a combination of testing and calculation. The 24-month Frequency is appropriate since significant degradation of the CBAC system is not expected over this time period.

The NRC staff evaluated the proposed SR associated with the proposed new LCO 3.7.7 and finds that it is appropriate for ensuring the operability of the equipment specified in LCO 3.7.7.

Specifically, CBAC subsystem heat removal capability is to be verified with testing/calculation at a frequency consistent with other HVAC TS systems. In addition, the SR Frequency is appropriate for the CBAC system verification of heat load removal capability via testing/calculation. The design heat loads or heat removal capacity is not expected to change over this time period since one division is always operating and in service in Modes 1, 2, and 3.

The NRC staff concludes that the proposed SR is acceptable because it meets the requirements of 10 CFR 50.36(c)(3) for SRs because it assures that the necessary quality of systems and components will be maintained, that facility operation will be within safety limits, and that the LCO will be met.

3.5 Technical Conclusion Based on its review of the application, supplement, and USAR, the NRC staff concludes, as discussed above, that the proposed new TS 3.7.7 is acceptable. This is because the TS LCO 3.7.7 contains requirements for operability of two CBAC subsystems, which the NRC staff determined provides for the lowest functional capability or performance level of equipment required for safe operation of the facility, and, therefore, meets the LCO requirements of 10 CFR 50.36(c)(2)(i).

Additionally, per the regulation, 10 CFR 50.36(c)(2)(ii), the proposed TS for the CBAC system satisfies Criterion 3 because a TS LCO must be provided for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a OBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The CBAC system provides essential cooling to components important to safety such as alternating current electrical buses, direct current batteries, and chiller equipment.

Further, the proposed TS 3.7.7 SR is acceptable because it meets the requirements of 10 CFR 50.36(c)(3) because the SR assures that the function of the systems will be maintained.

The NRC staff evaluated the proposed changes against the applicable design requirements listed in Section 2.4.1 of this SE. The NRC staff finds that the proposed changes for Modes 1, 2, and 3 operations, as they relate to the proposed new TS 3.7.7, remain consistent with the GDCs because the design requirements related to natural phenomena, environmental, electrical, and cooling water design and testing will continue to be maintained.

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing RBS requirements for customary terminology and formatting. The NRC staff found that the proposed changes were consistent with Chapter 16 of NUREG-0800.

3.6 Administrative Correction The licensee requested to correct errors in the RBS Facility Operating License No. NPF-47, Appendix C "Antitrust Conditions" that were inadvertently introduced during a request for an Order approving a transfer of the license. In the request submitted on June 10, 2014 (Reference 3), as supplemented by letters dated October 9, 2014, December 31, 2014, and January 30, 2015 (References 4, 5, and 6, respectively), the licensee stated that Appendix C of the RBS license contains antitrust conditions, but that no changes to these conditions were required as a result of the proposed license transfer. The NRC staff then issued an SE and Order approving the transfer of the license dated August 14, 2015 (Reference 13).

Subsequently, the NRC staff issued a conforming amendment to the license dated October 1, 2015 (Reference 14).

The licensee stated in its LAR (Reference 1) that the error was an omission of the markups of Appendix C to identify the new company in conformance with the license transfer. As a result, the conforming amendment was issued without a change to the name of the licensee in Appendix C, and it retained reference to the previous company name: Entergy Gulf States Louisiana, LLC.

The NRC staff reviewed the licensee's submittals dated September 8, 2017, June 10, 2014, October 9, 2014, December 31, 2014, and January 30, 2015; the NRC staff's Order and SE dated August 14, 2015; and the NRC staff's conforming amendment dated October 1, 2015.

The NRC staff noted in its Section 6.0, "Antitrust Review" of the SE dated August 14, 2015, that the NRC does not review antitrust conditions of post-operating license transfer applications, thus, no antitrust review was required or authorized. The NRC staff also stated that no changes to the antitrust conditions were required as a result of the proposed license transfer. However, the facility name provided in the antitrust conditions should have been changed in the conforming amendment to reflect the new licensee of RBS.

Based on the above, the NRC staff determines that the omission of the name change from Appendix C of Facility Operating License No. NPF-47 for RBS, from Entergy Gulf States Louisiana, LLC, to Entergy Louisiana, LLC, was an administrative error. Thus, the NRC staff concludes that changing the name in Appendix C of the RBS Facility Operating License from Entergy Gulf States Louisiana, LLC, to Entergy Louisiana, LLC, is 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 on June 21, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on January 30, 2018 (83 FR 4291 ). The amendment also relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

Maguire, W. F., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "License Amendment Request (LAR): Technical Specification 3.7.7, 'Control Building Air Conditioning (AC) System,' Administrative Correction to Antitrust Conditions in Appendix C of the Operation License," dated September 8, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17255A463).

2.

Maguire, W. F., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Responses to License Amendment Request (LAR) Technical Specification 3.7.7,

'Control Building Air Conditioning (CBAC) System,' NRC Request for Additional Information (RAI), River Bend Station, Unit 1," dated March 28, 2018 (ADAMS Accession No. ML18087A090).

3.

Mccann, J. F., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Entergy Operations, Inc., River Bend Station Unit 1 & ISFSI, Docket Nos. 50-458 &

72-49, Waterford 3 Steam Electric Station & ISFSI, Docket Nos. 50-382 & 72-75, Application for Order Approving Transfers of Licenses and Conforming License Amendments," dated June 10, 2014 (ADAMS Accession No. ML14161A698).

4.

McCann, J. F., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Entergy Operations, Inc., River Bend Station Unit 1 & ISFSI, Docket Nos. 50-458 &

72-49, Waterford 3 Steam Electric Station & ISFSI, Docket Nos. 50-382 & 72-75, Updated Application for Order Approving Transfers of Licenses and Conforming License Amendments," dated October 9, 2014 (ADAMS Accession No. ML151548588).

5.

Ford, B. S., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Notice of Change in Corporate Form of Entergy Louisiana Holdings, Inc. and Update to Application for Order Approving Transfers of Licenses and Conforming Amendments,"

dated December 31, 2014 (ADAMS Accession No. ML14365A404).

6.

McCann, J. F., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Responses to NRC Request for Additional Information Regarding Application for Order Approving Transfers of Licenses and Conforming License Amendments," dated January 30, 2015 (ADAMS Accession No. ML15030A495).

7.

Warnick, G. G., U.S. Nuclear Regulatory Commission, letter to William F. Maguire, Entergy Operations, Inc., "River Bend Station - NRC Integrated Inspection Report 05000458/2016001 and Final Significance Determination of Green Finding; NRC Inspection Report 05000458/2016008," dated May 11, 2016 (ADAMS Accession No. ML16132A144).

8.

Olson, E.W., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Interpretation of Technical Specifications, River Bend Station - Unit 1,"

dated August 4, 2015 (ADAMS Accession No. ML15231A111 ).

9.

Kim, J., U.S. Nuclear Regulatory Commission, letter to Vice President, Operations, Entergy Operations, Inc., "River Bend Station, Unit 1 - Request for Interpretation of Technical Specifications (CAC No. MF6586)," dated September 19, 2016 (ADAMS Accession No. ML162248075).

10.

U.S. Nuclear Regulatory Commission, "Standard Technical Specifications, General Electric BWR/6 Plants," NUREG-1434, Revision 4.0, Volume 1, Specifications, dated April 2012 (ADAMS Accession No. ML12104A195).

11.

U.S. Nuclear Regulatory Commission, "Standard Technical Specifications, General Electric BWR/6 Plants," NUREG-1434, Revision 4.0, Volume 2, Bases, dated April 2012 (ADAMS Accession No. ML12104A196).

12.

U.S. Nuclear Regulatory Commission, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," NUREG-0800, Chapter 16, Revision 3, "Technical Specifications," dated March 2010 (ADAMS Accession No. ML100351425).

13.

Wang, A. B., U.S. Nuclear Regulatory Commission, letter to John F. Mccann, Entergy Operations, Inc., "River Bend Station, Unit 1 and Waterford Steam Electric Station, Unit 3 - Orders Approving Direct and Indirect Transfer of Licenses and Conforming Amendment," dated August 14, 2015 (ADAMS Accession No. ML15138A440).

14.

Wang, A. B., U.S. Nuclear Regulatory Commission, letter to Vice President, Operations, Entergy Operations, Inc., "River Bend Station, Unit 1 - Issuance of Conforming Amendment to Reflect the Transfer of Facility Operating License No. NPF-47 from Entergy Gulf States Louisiana, LLC to Entergy Louisiana, LLC," dated October 1, 2015 (ADAMS Accession No. ML15265A116).

Principal Contributors:

L. Wheeler, NRR/DSS/SCPB N. Karipineni, NRR/DSS/SCPB M. Hamm, NRR/DSS/STSB C. Basavaraju, NRR/DE/EMIB Date: July 31, 2018

ML18177A387 OFFICE NRR/D0RL/LPL4/PM NRR/D0RL/LPL4/LA NAME LRegner PBlechman DATE 7/13/18 7 /13/18 (w/comments)

OFFICE NRR/DE/EMIB/BC*

OGG NAME SBailey JWachutka DATE 5/24/18 7/20/18 RidsNrrLAPBlechman Resource RidsNrrPMRiverBend Resource RidsRgn4MailCenter Resource LWheeler, NRR NKaripineni, NRR MHamm, NRR CBasavaraju, NRR NRR/DSS/STSB/BC*

NRR/DSS/SCPB/BC*

VCusumano SAnderson 6/26/18 6/26/18 NRR/D0RL/LPL4/BC NRR/D0RL/LPL4/PM RPascarelli LRegner 7/30/18 7/31/18