ML20043D303
| ML20043D303 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 06/04/1990 |
| From: | Plunkett T GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20043D305 | List: |
| References | |
| GL-88-01, GL-88-1, RBG-32948, NUDOCS 9006070350 | |
| Download: ML20043D303 (12) | |
Text
{{#Wiki_filter:' I L
. i e s .
O GULF STATES UTILITIES COMPANY N Dn W ADUN POM OWG M M . M FAOOWMt (DOWW UT4 an Aconi ou cu = m enu
)
June 4 , 1990- j RIG 32948 File Nos. G9.5, G9.42 U. S. Nuclear Regulatory Catmission ~; Document Control Desk Washington, D.C. 20555: ! Genticmont i River Bond Station - Unit 1 ' Docket No. 50-458 i Gulf States Utilities (GSU) Ccupany hereby files an application to amand the River Bend ' Station - Unit 1 Technical Specifications, Appendix A to Facility Operating License NPP-47, pursuant to 10CFR50.90. This application is filed to request changes in accordance with guidance provided in Generic Icttcr 88-01. These changes will revise specification '4.0.5, 3.4.3.1 ;
~
and 3.4.3.2 to address IGSCC concerns identified in the generic letter. The attachment to this letter and its enclosures provide ; 3 the justifications and proposed revisions to the Tecimical ! Specifications and Bases. Your prunpt attention this application is appreciated. , i Sincerely, ! C T. F. Plunkett General Manager Business Systems and Oversight River Bond Nuclear Group I!AE/I'JI /pg Attactwnts f 9_0060703so 900604_ -up P s[, g ;
- p ' , 1 s
m- ,: 1 r U '# f
' ! 5: I G; i(4 ;
si '
-. , - ..' 1 c '-
cc UIS'.1 Nuclear lRegulatoryCmmission-
. Region IV L611 Ryan Plaza Drive, Suite 1000 Arlington, TX -.76011
. 3.L
'NIO. Resident Inspectorg l Post Offico Box 1051-
# St. Francisville, IA 70775.
Mr. ' Walt 'Paulson . . U.' S. Nuclear Regulatory Cmmission
'One White Flint North 11555 Rockville Pike .
-Bockvillo, MD '20852._ - '
- Mr. William !!. Spell, Administrator- ;.1 >
-n-' ~ Nuclear. Energy Division- __ _.. .
latislana Department 'of: Environmental Quality 3 ., L P; O. Box 14690:
' Baton Rouge, IA _ -70898-1 t i 1
o .g
.x .f } '
o -- q-
- i
.3 1
y 1 1 i i 1
~
9 f
'I
UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA ) ; PARISH OF WEST FELICIANA- ) . ') Docket No. 50-458 i In'the Matter of ) ) GULF STATES UTILITIES COMPANY. ) (River Bend Station - Unit 1) AFFIDAVIT-T. F. Plunkett,- being duly sworn, states that he is-a- j General Manager - Business Systems and Oversight- for -Gulf i States Utilities Company; that he is authorized on the.part of l said company to sign and file with the Nuclear. Regulatory .} Commission the- documents -attached hereto; and that all such .; documents are true and correct to the best of his knowledge, l information and belief. l 1 T. P. Plunkett Subscribed and sworn to before me, a Notary Public in and for the State and-Parish above named, this 3 b day. of j b r i Ad , 1990 . My Commission expires-with Life. ! U !
)
l 0 0 CL11d1CL ) . Claudia F. Hurst
-M Notary Public in and for - ..1 West Feliciana Parish,~ Louisiana !
j 1 i
a ATDOM!NT GRP STNITlS LFfILITIES COP @ANY RIVER BEPO S'IRTIN IJCENSE NPF-47 , RFEIOR 000DNP SYSWM :! (89-06) ) L Licensing document: Technical Specifications Items:4.0.5 pages 3/4 0 i 3.4.3.1 3/4 4-10 3.4.3.2 3/4 4-11 REASON FOR REQUFSF In accordance with 10CFR50.90, a revision to the River Bond Station (RBS) I
}
Unit 1 Technical Specifications, Appendix A to Pacility Operating License -) NPF-47, is being requested. This change request responds to NRC Generic Ictter (GL) 88-01 dated January 25 ,1988, which requires > licensees -with l piping susceptible to intergranular; stress corrosion to modify their i operating licenses to place additional requirements in specification 4.0.5 i (Applicability:' Surveillance Requirements) item 'f' in accordance with the ; staff positions included in NBC Generic Intter 88-01. The GL also requests j modifications to specification 3.4.3.1 to limit operation with the sump , flow monitoring system inoperable and specification 3/4.4.3.2 to require a shutdown when tutidentified leakage increases -2 gpn in 24 hr. DESCRIPTION
.j A Nuclear Regulatory Cmmission _ (NRC) study of intergranular stress- i corrosion cracking (IGSCC) found in BWR austenitic-stainless steel piping (
near weldments resulted in the developnent of Nuclear Reactor Regulations- t NUREG-0313, " Technical Report on Material Selection and Processing f Guidelines for BWR Coolant Pressure Boundary Piping." Addressed during this study were NRC I&E Bulletin 82-03, " Stress Corrosion Cracking in i Thick-Wall, Large Diameter, Stainless Steel Recirculation System Piping.at NR Plants" and NRC I&E Bulletin 83-02, " Stress Corrosion in Large- ' Diameter Stainless -Steel Recirculation System Piping at BWR Plants." On January 25, 1988, the NRC stated their position on IGSCC in NRC GL 88-01, ,
"NRC Positions on IGSCC in BWR Austenitic Stainless Steel Piping." Tha GL included the requirements tot j I. Change the Technical Specifications to incorporate the NRC position on schedule, methods, personnel and sample expansion.
II. Initiate a plant shutdown when any leak detection system indicates an increase of unidentified :eakage in excess of 2 gpn within a period of i 24 hrs or less. i 1
1 3
- {
~
.III. Monitor the sump' 1cvel every. 4 hrs when the systm is a fixed- }
. measurement-interval ~
i
' 'IV. Limit outage time to 24 hrs for instruments associated with each stmp and then initiate shutdown, t
To address these requirements CSU is proposing changes to specifications i 4.0.5,.3.4.3.1 and 3/4.4.3.2 as discussed below.- f Specification 4.0.5: j An item 'f' will be added to reference the NfC reemnendations ; included .. in the GL, The River Dend Station Inservice Inspection (ISI) 1 Plan will be also be revised to reference NfC GL 88-01 and' incorporate tho' staff's position concerning IGSCC. .Also, the RBS Updated Safety Analysis Report (USAR) will be revised accordingly. .RBS, procedures . related to ISI' of' piping welds will be revised to reference NTC GL' -! 88-01. The scheduling of the ISI examinations will' be performed in , accordance with ' the River Bend Station ISI Plan, .which will continue - . to be subnitted to the NRC for review. Specification 3.4.3.1 l The design of the RBS drywll leak detection systems are described in Section 5.2.5.1.1 of the_ USAR. 'Ihe systes include the ;two' radioactive monitoring systems of gaseous and particulate activity, the drywell cooler condensate flow and the simp drain- flow monitoring. systems. The design and . operation of the radioactive .and cooler condensato systems will remain as previously described. The simp drain flow system consist of two subsystems,'ono locatedIin f the general drywell space at the 81 ft. elevation (floor. simp) andLthe ) other under the reactor vessel at 73 ft, elevation (podestal stap) . . l Both of the simps are 600 gal capacity stmps. . The flow rato fran each ! of these sumps are added to obtain the total flow rate. During the I perfornance of a surveillance ~ or other loss of the progranmable-(K') , operations ' personnel have a procedure (SOP-0104) to controller ianually calculate the sump flow, i ! The prrx:odure detennines empliance with specification 3.4.3.2 -- i Idntiting Condition for Operation (IID) requirements 'b' (5 gpn - unidentified) and 'c' (25 gpn total average over 24 hrs.). This ! procedure' is performed by recording the atmp levels in gallons prior to, and after, pumping the sumps; thereby, allowing accurate 1 determination of leakage volume, which can then be converted to a leakage rate for the period that the PC is unavailable which providing : the information necessary to ccnply with ICO 'b'. The level i indication instrtmentation for each step is independent of the PC and i the other sump. This procedure also maintains the 24 hour total leakage while the PC is unavailable which provides the information necessary to cmply with ICO 'c' . This procedure will be revised to i 2 f i
\
i
- 4
- e e
include additional instructions for the proposed specification 3.4.3.2 ! ICO item 'e', '1he PC- is an operator convenience which alerts the operator prior to leakage reaching the respective technical specification limits. Because the~ manual method provides emplete information to show canpliance with the license, loss of those canponents which do not inhibit the operator fran obtaining identical infomation does .not result in the inoperability of the flow L nnnitoring system. Also, the instnanentation is located in the containment'and can therefore be-repaired during power operations. During the loss of a single sump subsystem, . GSU' proposes to allow plant operation for the limited period of 72 hours to'rupair nr replace any inoperable . canponents, while. depending on the other primary leak detection systems. This new ACTION would also require empliance with ICO items 'a o and 'c's thereby, ensuring sufficient
- diverso leak detection is available. The proposed ACTION statement would still require plant shutdown if both- drywell sump level subsystems becono inoperable, as required by GL 88-01. An evaluation by RBS staff indicates that the 24 hour - shutdown action requirement upon loss of all sturp flow monitoring,'would often be insufficient to-affect repairs and perform the required surveillance to a single-subsystem to declare it OPERABLE. As a resalt, the plant could be forced to shutdown with one drywell sump flow subsystem and other leak' detection capability ranaining OPERABLE. This new ACTION is also based on the low probability of an occurrence of an IGSCC leak . during these periods due to the limited time period spent in this condition.
The use of the radiation monitoring systems to identify a significant increase of leakage in reactor coolant is , based on canpliance with 10-1.45 which recamonds that diverse instrumentation be capable of detecting a 1 gpn increase in reactor coolant leakage. The radiation nonitoring system is discussed in 'Section 11.5.2.1.3.4 and Table-11.5-1 of the USAR. The nonitors are powered fran a safety-related class 1E source (on site backup), are seismically qualified and have - ranges which exceed Regulatory Guide . (IC) 1.45 recamondations. The-10 also encourages the use of alternate systems "to assure effective monitoring during periods when sono detection systems may _ be. L ineffective or inoperable." This system is ' designed with alam . l points at 1 and 5 gpn; thereby, providing. the operator :an effective correlation to equivalent stunp. flow measuranents. To assure continued l reliability of these instruments, actual primary coolant activity is used to establish the setpoints and periodically updated as necessary, again in agreement with 10 1.45. The present procedure used to l respond to high drywell radiation level directs the chemistry group to sample both the drywell ntnosphere and the reactor coolant to determine the extent and source of the. airborne activity. The plant process canputer also collects the data fran the previous 24 hours and . displays the infonnation, with the background level, to the operator; thereby, providing further information to determine actual plant conditions. 3
4 The use of this systm will also provide information to confirm empliance with specification 3.4.3.2 requirements during the action period. This position is supported by the IIcating, Ventilation and Air Conditioning system design in the drywell as described in USAR section 9.5 and shown on USAR Figuru 9.4-8. ' The configuration of this system shows for a leak in the drywell the ait flow' will result in both sumps and the other leak detection systems being available to mnitor the leakage and therefore the leakage 'can be monitored by alternate methods. GSU proposes to change the format of the ACTION statement to clarify the requirements for effective operator response to the loss of leak detection equipnent. The proposed revision would continue to require three systems to be operable or entry into an ACTI m would result. 'If ICO items 'a' or 'c' became inoperable, operation may. continue for 30 days provided ' grab' sampling is conducted for. inoperable radiation monitors. The new ACTIm also climinates the ability to operate 30 days with no drywell sump drain flow mnitoring, as -required in GL 88-01, while allowing sufficient time to return cmponents of the level instrumentation system to OPDW3II status. The use of this 72 hour outage time is dependant upon utilizing alternate methods of leak detection to provide information. on a change in . leak. rate. GSU proposes that this request satisfies the intent of GL 88-01 and provides sufficient protection to the health and safety of the public. Specification 3.4.3.2. The new item 'e' .to the ICO provides -a new leakage rate' limit as described in the GL 88-01. 'Ib accmplish the new mnitoring requirment GSU will use the present drain sump monitoring system as the primary source of information. It is requested that this only be applicable to operational condition 1 since during a startup, the-leakage could increast during initial filling or establishing flow and prussurization of the reactor coolant pressure boundary which are not indications of IGSCC. This limitation is based on the low probability. of an occurrence of an IGSCC leak during startup periods due to. the limited time period spent in these operational corditions and the lower risk due to the more conservative plant conditions. Radiation monitors will only be used in those limited cases where the action requirements of 3.4.3.1.b are entered and continued empliance with 3.4.3.2 limits must be demonstrated. During periods when the floor or pedestal sumps are inoperable, GSU proposes to utilize the radiation monitoring system to identify significant changes in drywell leakage. The use of the radiation mnitors is based on the designed setpoints of 1 gpn in equivalent coolant leakage as discussed in USAR section 11.5.2 and 5.2.5 of the SER During the limited period when the primary drywell flow monitoring leak detectim is inoperable the use of this alternative will provide the operator prmpt warning of significant changes in leakage fran the reactor coolant pressure boundary UCPB) . Because the operator will be aware of changes in RCPB 4 t
7-leakage flw and the inoperability of the sump flw nonitoring instrunentation does not result in a direct challenge to this boundary and the lw probability of an-occurrence of an-IGSCC leak during these j periods due to the limited time period spent in this condition, GSU { propres this ACTION meets the intent of specification 3.4.3.2 limits. 1 I 'Ihe nw its .'e' will also be referenced in ACTION b to provide the associated direction upon detecting increased leakage over a short ) period. The inclusion of the 2 gpn increase por day limit in this. action will allow the plant operators sufficient tire to deteunine:
- 1) the source of the leakage and isolate the cmponent thereby returning the plant to empliance with the 100, or j
- 11) the leakage is not frcm the reactor coolant pressure boundary. .!
(RCPB) again returning the plant to empliance with the Iro, by i identifying the leakage is not from the RCPB, or q iii) the increase in leakage is not indicate of an IGSCC leak such that the 2 gpn/ day rate is not sustained (the 5 gpn total i unidentified leaxage limit will remain). River Bend has experienced small prmpt increases in unidentified Icakage in the past which quickly stabilize at a constant' flowrate, j vhen the source of the leakage is found on the following entry into the drywell the comon cause is small leaks frm valve packing, pump seals or fittings which are not IGSOC susceptible and would not be expected to increase. 'Ib date no IGSCC RCPB leakage has becn found at ; RBS and the continuing ISI program is expected to identify susceptible j material before leakage occurs. Also as discussed above, the present j plant procedures result in samples of the reactor coolant, drywell ' atmosphere and sump discharge being evaluated when the drywell leakage [ rate or source is questioned. Because of the possibilities-of short i term increases in leakage GSU proposes to use the 4 hour period in ! ACTION b to identify, isolate or allow the leak to stabilize (less - F than a 2 gpn/ day rate) and if successful exit the shutdown action. , i GSU believes this position is in cmpliance with the Generic letter ; since the plant will continue to be shutdown for leakage which i continues to increase also the time period allowed to address increases in leakage is limited to address an increasing leakage the 5 gpn total unidentified leakage limit will continue to be emplied with. Information will be added to the basis of specification 3/4.4.3.2 to provide operator guidance in detennining the appropriate response to an increase in leakage. 1 1 5
( y
-{
Specification 4.4.3.2.1. GSU's request to maintain the present mnitoring frequency of once por 12 hours is based on the following: RBS Operations shifts are conducted on a 12 hour rotation. A L requirement. of less than 12 hrs would create an administrative. buztlen to schedule and track the requested revision. ; Any significant change in' leakage will be alamed in the ' main control . rom by the present monitoring systems which include the 1 gpn alert on the particulate and gaseous radiation monitors and the 5 gpn setpoint on the sump flow monitor. Note, the 5tgpn setpoint is calculated by the PC on a period of less than 1 hr-
.which results in a more sensitive instrument to short term
..?
increases. This increased sensitivity often results in higher leak rate readings than actual over short time periods which results in conservative infomation being relayed to the operator. GSU has detennined the present monitoring systems which are installed are in excess of the RG-1.45 and Standard Review Plan requirements and meet the intent- of the reduced monitoring period reccmnended in GL88-01. The periodic confirmation by plant staff personnel will enhance the operators knowledge of the unidentified leakage rate. Therefore this time period has been detennined to_ be sufficient- to detect a change in leakage while not subjecting the plant to an unnecessar/ administrative burden. A change to the Basis of specification 3/4.4.3.1, " Reactor Coolant Systm Icakage," for the drywell and pedestal floor sump drain flow monitoring systems is added because loss of the autmatic system does not constitute loss of the system provided a manual procedure is used. This is justified' ' since the inputs to the manual method are the same. as to the cmputer. Also, the substitution of ' grab' samples for the drywell particulate and gaseous mnitors allows for continued monitoring of' the function while d normal cmponents are inoperable. A change to the Basis of specification 3/4.4.3.2, " Operational Leakage" identifying the use of the drywell radiation monitors as alternate means to monitor . leakage rate while the sump flow mnitoring system is inoperable and information on the action recuirements are added. The use of the radiation monitoring continues to provide the operators with drywell leakage infonnation during sump flow indication system outages. Therefore, , leakage is mnitored and the control rom personnel can be alerted in an appropriate time frame. The applicable actions to be taken are discussed above under specification 3.4.3.2. Because this is a change to the bases there is no change to the technical specifications as defined in 10CPRSO.36 and therefore no requirment to ' subnit a 'No Significant Hazards Consideration' determination. 6 i
As an editorial change the note
- on specifications 4.4.3.1.d and 4.4.3.2.2.a can be removed because the referenced refueling outage is past, i
NO SIGNIFICNTI' HAZARDS CONSIDERATION' As required by 10CFR50.92, the following is provided to the NRC in support of a "no significant hazards considerations" determination I. Probability or Consequences of an Accident Previously Evaluated: Ebr specification 4.0.5 there will be no increase in the probability or the consequences of an accident previously evaluated because there are no design changes or nodification to plant operation associated with this anondment. This change will only be an enhancement of the ~ inservice inspection surveillance involving IGSCC and does not reduce
- any of the ASME B&W Code, Section XI - Division-1 requirements, j For specifications 3.4.3.1 and 3.4.3.2, there is no increase in. the .!
probability or consequences of an accident previously evaluated i because there are no changes to the design or operation associated l with this amendnent. This change will only provide further restriction on the operation of the plant when equipnent is inoperable. - 1 II. Possibility of a New or Different Kind of Accident: i Since this amendment is to change documents related to inservice 1 inspection surveillance and place additional restrictions on plant operation with inoperable equipnent there is no possibility of a new of different kind of accident. If indications are identified in d piping, the evaluation will~ be performed in accordance with ASME B&PV ! Code, Section XI - Division 1, already identified in the RBS Technical Specifications. 1 For specifications 3.4.3.1 and 3.4.3.2, there is no possibility of a , new event because there are no changes to the design'or operation j ansociated with this amendment. This change will only provide- further a restrictions on the operation of the plant when equipnent is j inoperable. 4
)
III Margin of Safety: There will not be a reduction in the margin of safety due to this I amendment since this change to the RBS 'Ibchnical Specifications will ; increase the number of inservice inspection surveillance and further ' instrict operation with inoperable equipnent. With frequent ; surveillances being performed, chances of an accident are less likely ' to happen. With increased restrictions on operation with inoperable equipnent resulting in plant shutdown, this change will not result in a reduction in the margin of safety. .g i 7 i s
l As discussed above the proposed change does not increase the probability or consequences of a previously evaluated accident and will not create- a new . or difforent accident.. Also because adequate margin has been shown with t respect to all design limits, the proposed change does not result- in a i significant reduction to -the margin of safety. Therefore GSU concludes -; there are no significant hazards involved. REVISED TFU NICAL SPECIFICATIM , W e requested revisions are provided in Enclosure I REVISED TDCINICAL SPECIFICATION BASFS . . We requested revision is provided in Enclosure.II SCHEDULE FOR ATTAINING COMPLIANCE { River Ikmd Station is currently in canpliance with this specification. The
- modifications _to the ISI plan will be initiated and the specifications will- -
be implenented within 60 days after receiving the approved amendment frun
~ '
the NRC. NOTIFICATION OF STATE PERSONNEL A copy of this amendment request has been provided to the State of-Iouisiana, Department of Environmental Quality - Nuclear Energy Division. > ENVIR0tM WTAL IMPACT APPRAISAL Gulf States Utilities Company (GSU) has reviewed the proposed license- 'i amendment request- against 'the criteria. of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards a consideration, nor increase the types and. amounts of effluents'that may be
~
released offsite, nor significantly increase . individual or. cumulative occupational radiation exposures. Thus, GSU concludes.that'the proposed
- e change meets the criteria given in 10CPR51. 22 (c) (9) for aacategorical exclusion from the requiranent for an Environmental Impact Statement.
r bi
-i 8
, - ~
r n.; ENCLOSURE I. INSElfPS
-I. Specification 4.O.5 }
- f. The -Inservice Inspection Program (ISI) for piping susceptible to.- I Intergranular - Stress Corrosion Cracking (IGSOC) shall- be '
performed- in laccordance with--the NHC positions included in. Generic Letter 88-01. - s II. . Specification 3.4.3.1 ACTION a
- a. With leak detection systans 'a' and/or' 'c' inoperable . operation l nay continue for up to _30 days _ provided grab sanples' are obtained- !
and analyzed at least once: per. 24 hours 'for the inoperable i radiation nonitors; otherwise, beLin IKyr SiltrIDOWN'within the next 12 hours and in COm SiitrIDOWN within the following124 hours; ACTION b
- b. With the drywell floor or pedestal sump' drain ~ flow nonitoring -
4 subsystein inoperable,_ operation may continue for:up to 72 hours provided leak detection systems 'a' Lor 'c' is' OPERABLE;= s otherwise, be in at 1 cast IKyP SlitrrDOWN within the rext' 24 hours - ' and in COLD SHlHDOWN within the following 24 ' hours.' III. Specification 3.4.3.2 -
- UX) e i
- e. 2 gpn UNIDINTIFIED LEAKAGE increase within'any period'of 24. hours or less (Applicable in OPERATIONAL ~ CONDITION 1 -only)
't i
I i
)}}