ML20059F396

Safety Evaluation Supporting Amend 47 to License NPF-47

ML20059F396
Person / Time
Site:	River Bend
Issue date:	08/31/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20059F388	List: ML20059F383 ML20059F396
References
GL-87-09, GL-87-9, NUDOCS 9009110200
Download: ML20059F396 (5)

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UNITED STATES I

NUCLEAR REGULATORY COMMISSION i

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WASHINGTON, D. C. 20bs6 e

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

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RELATED TO AMENDMENT N0. 47 TO FACILITY OPERATING LICENSE NO. NPF-47 GULF STATES UTILITIES COMPANY RIVER BEND STATION, UNIT 1 DOCKET NO. 50-458 INTRODUCTION By letter dated September 30, 1988 and supplemented by two letters dated June 6, 1990, and letters dated June 26, 1990, and August 22, 1990, Gulf States Utilities Company (GSU) (the licensee) requested an amendment to Facility Operating License l

No. NPF-47 for the River Bend Station, Unit 1.

The proposed amendment would change the plant Technical Specifications (TSs) based on the recommendations provided by the staff in Generic Letter (GL) 87-09 related to the applicability of limiting conditions for operation (LCO) and the surveillance requirements of i.

the TSs 3.0 and 4.0.

Specifically, the licensee has requested the following revisions to TSs 3.0.4, 4.0.3 and 4.0.4 as follows:

Specification 3.0.4 is revised to define when its provisions-apply; 1.e.,

when the affected action statements permit continued operation for an unlimited period of time, instead of defining when the provisions of Specification 3.0.4 do not apply.

Specification 4.0.3 is revised to incorporate a 24-hour delay in implementing Action Requirements due to a missed surveillance when the Action Requirements provide a restoration time that'is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Specification 4.0.4 is revised to clarify that "This provision shall not prevent,

passage through or to OPERATIONAL CONDITIONS as required to comply with Action Requirements."

L EVALUATION The changes proposed by the licensee have been reviewed considering the limitations set forth in GL 87-09 for TSs 3.0.4, 4.0.3 and 4.0.4 as follows.

B' Specification 3.0.4 GL 87-09 recognizes, in part, that Spacification 3.0.4 unduly restricts facility operation when conformance to the Action Requirements provides an acceptable

.. level of safety for continued operation in any mode.

For an LCO that has Action Requirements permitting continued operation for an unlimited period of time,. entry into an operational mode or other specified condition of operation 9009110200 900831 ADOCK0500gg8 DR

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should be permitted in accordance with those Action Requirements.

The restriction on change in operational modes or other specified conditions should apply only j

where the Action Requirements establish a specified time interval in which the 1

LCO must be met or a shutdown of the facility would be.'equired or where entry

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into that operational mode would result in enn y into an Action Statement with i

such time constraints. Mowever, nothing in the staff position stated in GL 87-09 should be interpreted as endorsing or encouraging plant startup with inoperable equipment. The GL 87-09 itself states that startup with inoperable equipment should be the exception rather than the rule.

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The licensee has provided confirmation that the remedial measures prescribed by the ACTION STATEMENT for each change involving Specification 3.0.4 is I

consistent with the Updated Safety Analysis Report and its supporting safety analyses.

Further, the licensee has provided confirmation and certification that appropriate administrative controls and procedures are in place for limiting 1

l the use of Specification 3.0.4 exceptions in conjunction with its proposed TS change submitted in response to GL 87-09.

Additionally, no changes are proposed that affect plant configuration, setpoints, operating parameters, or the operator / equipment interface.

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Based on review of the licensee's proposal, and confirmations related above, we conclude in granting the exceptions proposed in response to GL 87-09 that:

.(1) the remedial measures prescribed by the ACTION STATEMENT for each change involving the applicability of the Specification 3.0.4 exception should provide i

a sufficient level of protection to permit operational mode changes and safe long-term operation consistent with the plant's Updated Safety Ant:1ysis Report, and (2) the licensee has in place adequate administrative controls and procedures which will ensure that it will be the exception rather than the rule that startup

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of the plant with important safety features inoperable will occur.

We, therefore, find the following change to Specification 3.0.4 proposed by the l

licensee to be acceptable:

"Eatry into an OPERATIONAL MODE or_other specified condition shall nct be made when the conditions for the Limiting Condition for Oparation are not met and the associatcJ ACTION requires a shutdown L

if chey are not met within a specified time interval.

Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION Requirements when conformance-to them permits conti.1ued operation of the facility for an unlimited period of tist."

Additionally, in a letter dated June 6,1990, GSU submitted justifications for preplanned use of tre operating flexibility allowed by the change in TS 3.0.4.

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GSU proposed to appiy the flexibility of TS 3.0.4 to TS 3.4.9.2, " Cold Shutdown" and TS 3.9.11.2, "L)w Water Level".

TS 3.4.9.2 requires wo shutdown cooling mode loops of the RHR system be operable 1

and unless at least one recirculation pump is in operation, at least one

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.. k shutdown cooling mode loop be in operation in Operational Condition 4 (COLD SHUTDOWN). As stated in the Bases for TS 3.4.9.2, a single shutdown cooling mode loop provides sufficient heat removal capability for removing core decay heat and provides adequate cooling mixing.

The staff has reviewsw: GSU's justification for allowing a change in plant conditions to Operational Condition 4 while complying with the action require-ments of TS 3.4.9.2.

The justification was based on the fact that less decay heat is generated in Operational Condition 4, that the specific function of the required RHR shutdown cooling mode loop is completely replaced by the alternate method and that at least one ECCS is operable.

The staff finds preplanned use of the operating flexibility allowed by TS 3.0.4 is applicable while complying with the action requirements of TS 3.4.9.2 and is acceptable.

TS 3.9.11.2 requires two shutdown cooling mode loops of the RHR system be operable with one in operation in Operational Condition 5 (REFUELING) and with reactor cavity water level less than 23 feet above the top of the reactor pressure vessel flange.

The Bases for TS 3.9.11.2 states that with the reac.s*

vessel head removed and 23 feet of water above the reactor pressure vessel flange a large heat sink is available for core cooling and in the event of a failure of the operating RHR loop, there is adequate time to initiate alternate methods of decay heat removal or emergency procedures to cool the core.

The staff has reviewed GSU's justification for allowing a change in plant conditions while complying with the requirements of TS 3.9.11.2.

GSU's justi-fication was based on the fact that less decay heat is generated in this condition and specific functions of the RHR shutdown cooling mode loops are replaced by alternate methods.

The staff finds that the operating flexibility allowed by TS 3.0.4 is applicable while complying with the action requirements of TS 3.9.11.2 and is acceptable.

l Specification 4.0.3 In GL 87-09, the staff stated that it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed..because the vast majority of surveillances demonstrate the systems.

or components in fact are operable.

Because the allowable outage time 11rits of-some Action Requirements do not provide an e propriate time limit for performing a missed surveillance before shutdc.., requirements apply. the TS should include a time limit that would allow a delay of the required actions l

to permit the performance of the missed surveillance.

This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as.well as the safety significance of the delay in completion of the surveillance.

After reviewing possible limits, the staff concluded that based on these con-siderations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown Action Requirements apply.

Tt; 24-hour time limit would balance the risks associated with an allowance or l

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completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the j

surveillance can be completed.

1 This limit does not waivs compliance with Specification 4.0.3.

Under Specifi-cation 4.0.3, the failure to perform a surveillance requirement will continue '

to constitute noncompliance with the operability requirements of an LC0 and to bring into play the applicable Action Requirements.

Besed on the above, the following change to Specification 4.0.3 is acceptable:

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" Failure to perform a Surveillance Requirement within the allowed l

surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Candition for Operation.

The time limits of the ACTION Requirements are applicable at the time it is identified that a SURVEILLANCE REQUIREMENT has not been performed.

Compliance with the ACTION Requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION Requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Specification 4.0.4 TS 4.0.4 prohibits entry into an OPERATIONAL CONDITION or other specified condition until all required surveillances have been performed.

This could cause an interpretation problem when OPERATIONAL CONDITION chan0es are required in order to comply with ACTION statements.

Specifically, two possible a

conflicts between TSs 4.0.3 and 4.0.4 could exist.

The first conf 1:ct arises because TS 4.0.4 prohibits entry into an operational mode or other specified condition when surveillance requirements have not been performed within the specified surveillance interval.

The DECO proposed modification to resolve this conflict involves the revision to TS 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application of the Action Requirements, as explained above, and a clarification of TS 4.0.4 to allow passage through or to operational modes as required to comply with Action Requirements.

The second potential conflict between TSs'4.0.3 and 4.0.4 arises because an exception to the requirements of 4.0.4 is allowed when surveillance requirements can only be completed after entry into a mrfe or condition.

However, after entry into this mode or condition, the requirements of TS 4.0.3 may not be met because the surveillance requirements may not have been performed within the allowable.

surveillance interval.

The licensee proposed to resolve these conflicts by providing the following clarifying statement to TS 4.0.4:

"This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements."

The NRC staff his provided in GL 87-09 a clarification that:

(a) it is not the intent of 4.1.3 that the Action Requirements preclude the performance of surveillances allowed under any exception to TS 4.0.4, and (b) that the delay of up to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> + in TS 4.0.3 for the applicability of Action Requirements provides an appropriate time limit for the completion of surveillance require-ments that become applicable as a consequence of any exception to TS 4.0.4.

Consequently, the NRC staff finds the proposed changes to TS 4.0.4 acceptable.

Editorial Channes Editorial changes are being made to TS Table 3.3.7.1-1. TS 3.4.9.2 and TS 3.9.11.2.

Action 73 of TS Table 3.3.7.1-1 currently specifies HOT STANDBY as an operat'.a1 condition.

The term STARTUP is consistent with the operational conditions defined in the TS and will replace the HOT STAN08Y term. TSs 3.4.9.2 and 3.9.11.2 contain footnotes which were applicable until startup from the i

second refueling outage.

The second refueling outage has been completed, therefore, the footnotes are no longer needed.

l ENVikONMENTAL CONSIDERATION l

The amendment involves a change in a requirement with respect to the installation l

or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements.

The staff has determined that the amendment involves no significant increase in the amounts, and no signi-ficant 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 exposures.

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.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Section 51.22(c)(9).

The amendment also involves changes in recordkeeping, reporting 1

or administrative procedures or requirements.

Accordingly, with respect to these items, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR $51.22(c)(10).

Pursuar.t to 10 CFR 51.22(b), no environmental impact statement or environmental assassment need be prepared in connection with the issuance of the amendment.

CONCLUSION 4

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. The staff 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, and (2) such

'.ctivities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to the' common defense l

and security or to the health and safety of the public.

The staff therefore concludes that the proposed changes are acceptable.

Dated:

August 31, 1990

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l l-Principal Contributor:

C. M. Abbate L

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