ML20081B785

From kanterella
Jump to navigation Jump to search
Safety Evaluation Supporting Amend 76 to License NPF-47
ML20081B785
Person / Time
Site: River Bend Entergy icon.png
Issue date: 03/08/1995
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20081B783 List:
References
NUDOCS 9503160357
Download: ML20081B785 (15)
v • d • e


Text

_* *% s>g ft - UNITED STATES g j ' NUCLEAR REGULATORY COMMISSION - WASNINGTON, D.C. 20056 0001 A*****/-SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO APENDMENT 76 TO FACILITY OPERATING LICENSEE NO. NPF-47 L ENTERGY OPERATIONS. INC. RIVER BEND STATION. UNIT 1 DOCKET NO. 50-458 l

1.0 INTRODUCTION

By 1etter dated January 14, 1994, as supplemented by letters dated 1 November 10, 1994, and February 8, 1995, Entergy Operations, Inc. (E01), (the licensee), requested an amendment to~ Facility Operating License No. NPF-47 for the River Bend Station (RBS). The proposed amendment would remove the technical specification (TS) tables that include lists of components referenced in individual specifications and relocates the reactor vessel material specimen withdrawal schedule from the TSs to the updated safety analysis. report (USAR). Additionally, the TSs have been modified such that all references to these tables have been removed. Finally, the TSs have been modified to state requirements in general terms that include the components - listed in the tables being removed from the TSs. Guidance on the proposed TS-changes was provided by Generic Letter (GL) 91-08, " Removal of Component Lists from Technical Specifications," dated May 6, 1991. The February 8,1995, letter provided clarifying information that did not change the initial proposed no significant hazards consideration. determination 2.0 DISCUSSION Section 50.36 of Title 10 of the Code of Federal Regulations established the regulatory requirements related to the content of TSs. The rule requires that TSs include items in specific _ categories, including safety limits, limiting conditions for operation, and surveillance requirements; however the rule does not specify the particular requirements to be included in a plant's TSs.. The NRC developed criteria, as described in the " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Plants" (58 FR 39132), to determine which of the design conditions and associated surveillances need to be located in the TSs. The final policy statement adopted the subjective statement of the Atomic Safety and Licensing Appeal Board, ALAB 531, 9 NRC 263, 273 (1979), Portland General Electric Co. (Trojan Nuclear Plant) as the basis for the criteria. The Appeal Board stated, ... there is neither a statutory nor a regulatory requirement that every operational detail set forth in an applicant's safety analysis report'(or equivalent) be subject to a technical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval. Rather, as best we can discern it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the 9503160357 9003ca PDR ADOCK 05000458 P PDR

~ __-.4

y 2T,m; ;

'~ ~ 2 - 'S 2-imposition of: rigid conditions or limitations upon' reactor operation' is w~ ~ deemed necessary to obviateithe possibility of an abnormal situation.or? l Levent giving rise to an-immediate threat to the' public health and-safety." ~ i 'Briefly, the criteria 'provided by the final: policy statement are '(1). detection? of abnormal degradation of the reactor coolant pressure boundary,'(2) boundary ~' -conditions for design basis accidents and transients,-(3) primary success- ,i paths to prevent or. mitigate design basis accidents.and transients,-and 4 (4) functions determined to be:important to risk or, operating experience. The Conmiission's final policy statement acknowledged that'its implementation may.. - result in the relocation of existing TS requirements to. licensee ~ controlled. d . documents and programs. .GL 91-08 provides specific guidance on the removal;of component' lists from TSs. ~ when removal of the component lists do not. alter existing TS requirements or ' lthose components to which they apply. GL 91-01 provides guidance on ~ j -relocating the reactor vessel specimen withdrawal schedule from the TSs to the USAR.- 3.0 EVALUATION In accordance with GL'91-01, GL 91-08, and 10 CFR'50.90, the~ licensee proposed' .l the following changes to the RBS TS. The licensee's proposed changes are i discussed in the order in which the. associated' specification appears in the-RBS Technical Specifications. The staff's evaluation and conclusion follow each proposed change. j q (1) The TS index pages are being. revised to make editorial corrections to reflect the deletion of tables which contain component ~1ists or.to a reflect renumbering of pages due to deletion of large lists.7 'It is' proposed that the deleted pages be retained as denoted in the marked-up pages. The staff concludes that the proposed changes are acceptA1e based on the fact that they are administrative' in nature only (reflecting the TS~ changes evaluated below). j (2) It is proposed that Definition 1.32, PRIMARY CONTAINMENT INTEGRITY - FUEL l HANDLING, Items (a), (b), and (c), and ~ Definition 1.33, PRIMARY j CONTAINMENT INTEGRITY - OPERATING,' Items-(a), (b), (c),.and (d), be i revised by adding " primary" to each of the appropriate subparagraphs for clarification. 1 These changes are provided for clarification only and do not result in any technical change to the current TSs. Therefore'the staff finds'the proposed changes acceptable. (3) The licensee proposes to delete Footnote (***) to. Surveillance .l Requirement (SR) 4.3.1.2 and Footnote (p) to Table 4.3.1.1-1, associated with Reactor Vessel Steam Dome Pressure - High and Main Steam Line 'i Radiation - High (Functional Units 3 and 7). ~ l I t I I ,.-. -~ . ~

4: y ]h gj ]q w y+

}

y o 'Both.footnotestrefer to extensions associated with the first refueling. 1 j outage, which occurred in,1987, and are no longer necessary. This .i

proposed change is editorial and does not result in.a technical change to; jl the current' requirements.nTherefore,_the staff finds the. proposed,

. changes acceptable, j o (4) The_ licensee proposes to delete Footnote (*) toSR 4.3.2.2 and ~ Footnotes e ' (c) and (d) to Table 4.3.2.1-1, associated with Reactor. Vessel Water - j Level - Low Low Level 2, Reactor Vessel Water Level - Low: Low Low Level. m 1, Main Steam Line: Radiation - H;gh, Main Steam Line Flow .High,. Reactor l Vessel (RHR [ residual heat removal) Cut-in-Permissive) Pressure - High,- i and Drywell Pressure - High (Trip Functions 1.a, 2.a. 2.b,' 2.d, 3.a, 4.e, c .i 6.d 6.e, and 6.f). - 'All three footnotes refer to extensions associated with the first l refueling outage, which occurred in 1987, and are no longer necessary. j This proposed change is editorial and does not result in'a technical q change to the current requirements. Therefore, the staff finds the proposed changes acceptable. j (5) The licensee proposes to delete the " Valve Groups Operated By Signal" column and Footnote (***) from Table 3.3.2-1; revise Footnote (e) to 1 Table 3.3.2-1 to delete reference to' Table 3.6.5.3-1; and relocate ^ Footnotes-(a). through-(1) from the column " Valve-Groups Operated By Signal" portion of Table 3.3.2-1 to the associated individual trip' ], function.' The " VALVE GROUPS OPERATED BY SIGNAL" column, through reference to Tables d 3.6.4-1 and 3~ 6.5.3-1, identifies which valve group (s) each isolation 1 trip' function _affects and includes a number of notes which are associated with the trip function or the valve group (s). -The valve groups.are proposed to be deleted from the TSs and relocated to the Technical i Requirements Manual (TRM). The valve groups identified,in this TS are for information only and require a listing of the individual: valves -r' (associated with the groups) to be of use ~ The current listing of individual valves (associated with the groups) is currently provided in Table 3.6.4-1, " Containment and-Drywell Isolation _ Valves"'and Table 3.6.5.3-1, " Secondary Containment Ventilation System Automatic t Isolation." These tables are also being deleted from the TSs and i relocated to the TRM (see below). The valve groups are not. necessary to y support the actions or surveillances required.by the'TSs~. j 1 Footnote (***) to Table 3.3.2-1 is proposed to be deleted from the TSs and relocated to the TRM. This note refers the reader to Tables 3.6.4-1 and 3.6.5.3-1 for the list of affected valves. A listing of the valves' in the TSs is not necessary to support the actions or'surveillances required by the TS. Footnote (e) to Table 3.3.2-1 is proposed to be revised to delete t'he reference to. Table 3.6.5.3-1, which lists the secondary containment . ventilation system automatic isolation. dampers.- Table 3.6.5.3-1 'is being relocated to the TRM. With the proposed revision, the note identifies'in 1 i

a, my M -: 4 -- ' ~ .generalsterms that isolation dampers are also. actuated by the:tripf function. -The ' proposed. changes are administrative only, reflecting the deletion of E

Tables 3.6.4-1 and 3.6.5.3-1.

Therefore. the-staff finds. the proposed ' changes acceptable. .(6) The. licensee proposes.to revise Footnot'e (#). to Table-3.3.2-3 to delete-reference to-Tables 3.6.4-1 and 3.6.S.3-1. Tables 3.6.4-1 and 3.6.5.3-1 are being' relocated to'the'TRM'(as discussed below). With the proposed revision to the footnote, the SR has-been stated in general terms to apply to allLvalve~ isolation times. Additional guidance will now be found in the tables ~ relocated:to the TRM. p Therefore, the staff finds the proposed changes acceptable. (7)' The-licensee proposes to delete Footnote (##) to SR 4.3.3.2 and. SR 4.3.3.3, and Footnote (b).to Table 4.3.3.1-1, associated with Reactor Vessel' Water Level Low Low Low Level 1, Drywell Pressure - High,- LPCS [ Low-Pressure Core Spray] Pump Discharge Flow - Low, ~ LPCI [ Low-Pressure Coolant Injection] Pump Discharge Flow - Low, Reactor Vessel' Pressure 4 - Low, LPCI Pump Start Time Delay Relay, LPCS Pump Start Time Delay Relay, LPCI/LPCS Manual Initiation, and 4.16 kV Standby Bus Undervoltage (Trip. Functions A.I.a, A.I.b, A.I.c, A.I.d, A.I.e, A.I.f, A.I.g,-'A.I.h, B.1.a. B.I.b,-B.I.c, B.I.d, B.I.e, B.I.f, B.I.g, D.I.a, and 0.1.b)'.. Footnote (##) referred to a " Note C" in Table ~ 4.3.3.1-1 that had concerned the first refueling outage and had previously been deleted. Footnote B' referred to:an extension for the fifth refueling outage,owhich ended on June 29,-1994. These footnotes are no longer necessary and can be removed since the subject refueling outages have been completed. ~This proposed change is-editorial in nature and does not result in a technical-change to the current. requirements. The staff finds the proposed changes: acceptable. (8) The licensee proposes to dele'te Footnote (#) to SR 4.3.9.2 and Table 4.3.9.1-1, associated with Reactor Vessel Water Level'- Low Low Low Level and Drywell Pressure -' High '(Trip' Functions. l.c 'and 1.a). - These footnotes permitted an extension of the 18 month test interval until the completion of the first refueling outage, which ended in 1987, and are no longer necessary. This proposed change is editorial in nature and does not result in a technical change to the current requirements. The staff finds the proposed changes acceptable. (9) The licensee proposes to revise Limiting Condition for Operation (LCO) 3.4.3.2.d and SR 4.4.3.2.2 to delete references to Table 3.4.3.2-1. The proposed revisions delete the references to Table 3.4.3.2-1, " Reactor Coolant System Pressure Isolation Valves," which identifies those valves. The referenced Table 3.4.3.2-1 is being deleted from the TS and relocated to the TRM (as discussed below). With the proposed revision, the LCO and-

~l . d ;h

?

[-M

d y

_5_; j r 'the SR state that the'requirementsfin:each apply to reactor coolant: y e~ pressure' isolation' valves, in, general..: This proposed ' change is adminis-trative in' nature reflecting the relocation of. Table 3.4.3.2-1 to the - "m,'j .TRM. The' staff finds 1the' proposed change acceptable. L y -(10) The licensee proposes to: revise. ACTION Stitement 3.4.3.2.d ts' delete j ~ ~ reference to Table 3.4.3.2-2 and SR 4.4.3.2.3.to delete reference 1to

  • alarm setpoints contained in Table 3.4.3.2-2.

.l >4 o~ . ACTION Statement 3.4.3.2.d is proposed to be revised-to delete'th'e j reference to Table 3.4.3.2-2,1" Reactor Coolant System Interface Valves: 7 . Leakage Pressure Monitors," which is a list of those monitors. -) ~ SR 4.4.3.2.3 is also proposed to' be revised to delete the reference to R alarm setpoints contained in Table 3.4.3.2-2.. Table 3.4;3.2-2,' including 1 alars setpoints, is being deleted from the TS-and relocated to the TRM. -l eH The setpoints are not Limited Safety Settings as defined by110 CFR 50.36 and the proposed control by the licensee is acceptable. c With-the proposed revision, the action statement and the SR state the requirements-i in each apply to interface valve leakage pressure monitors'in general' 1 terms.. This proposed change is administrative in nature, reflecting the - 1 relocation of. Table 3.4.3.2-2 to the TRM.- The staff finds the proposed 1 changes acceptable. ~ (11) Table 3.4.3.2-1, " Reactor Coolant System Pressure lsolation-Valves," 'i i is proposed to be d(lated from the TS and relocated to'the TRM.. 1 d Table 3.4.3.2-1 currently denotes 'the valve number, function, and associated system for the reactor coolant system (RCS) pressure isolation-valves. i In July 1993, the NRC issued NUREG-1463, " Regulatory Analysis for.the lj Resolution of Generic Safety Issue 105:. Interfacing System ~ a Loss-of-Coolant-Accident (LOCA) in Light-Water Reactors." This report 1 concluded that the interfacing. system LOCA, which is the rationale for.~ 1 the RCS pressure isolation. valves being in plant ~ system design, is not a. i risk concern for boiling water reactors-(BWRs).: This is' also supported : j by the RBS Individual Plant Examination (IPE) for GL 88-20 which closes plant specific concerns relating to' Generic Safety Issue 105.~ The 1 results of the. RBS IPE conclude that the chance of an interfacing system LOCA causing a harsh operating environment for emergency core cooling l system (ECCS) equipment was negligibly small and the risk posed by an 1 interfacing system LOCA, given normal operating environment for ECCS 3 equipment (and thus generic failure probabilities for ECCS), is very _ small. The staff's review of the proposed chanr @termined that the relocation of Table 3.4.3.2-1 does not eliminate t-m airements for the licensee f to ensure that the RCS pressure isolation valves are capable of l performing their safety functi.a. Although Table 3.4.3.2-l~ is relocated from the TSs to the TRM, the information being relocated will be' -l ' controlled and subsequent changes reviewed in accordance with the change-control program described in TS 6.5.2. The staff finds the proposed j change acceptable. ) 1

[q w,a, C4 n ( ~~ ~ ^ ~ ~ ~ ^^^ I a-s 1 m [QQ kglg 1 ~, - s; - 6'-: -i ~ x av ~ l(12)2 fable 3.4.3.2-2:is 'also proposed to be' deleted' from!theLTSs> and' relocated j ^

  • '1 to the -TRM.. ; Table 3.4.3.2-2 currently denotesLinstrument: numbers, d

functionsFand alarm setpoints for RCS high/ low pressure interface valvei j a c-w ' leakage. pressure monitors. Alarm setpoints are typically addressed in; i iplant operational. procedures, however, sthese setpoints will' be relocated to the TRM.~ These-alarm setpoints' are not Limited Safety: Settings: as i* defined by:10 CFR 50.36;and the proposed control, by the licensee is L A acceptable. ~ j d The Linformation being relocated to the TRM fromLthis table is controlled-and: subsequent changes reviewed in accordance with the change control;_ . program described in Specification.6.5.2._'As'a result, the deletionLandi y subsequent relocation of this information'from.the TSs complies with the? - 1 ~ uidance contained in.GL 91-08.. The proposed change',:therefore, does'not; 'j ~ g result in a _ technical. change to the TSs.: The staff finds'the. proposed

)

change acceptable. .j l . (13) SR 4.4.6.1.3 is. proposed to be revised to delete the reference' to Table '-l 4.4.6.1.3-1, " Reactor Vessel Material' Surveillance Program - Withdrawal" 1 P Schedule." j The referenced Table 4.4.6.1.3-1 is being. deleted from the:TSs and j! ~ relocated to"the TRM (as discussed below).. The reference to the. table is for,information only and is not necessary to support the surveillance.. H . required by:the TSs.. The staff finds'the proposed change acceptable. j -(14) Table 4.4.6.1.3-1, " Reactor Vessel-Material Surveillance Program.- l Withdrawal Schedule," is proposed to be deleted;from the'TSs and' 'l relocated to the TRM. As stated in GL 91-01, this schedule is redundant = to -10. CFR _ Part;50,. _ j. Appendix-H (which requires. prior NRC-approval of changes ;to the specimen .i withdrawal: schedule). Therefore, it' is unnecessary to retain this table? j 5 in the-TSs. The specimen withdrawal schedule. is not necessary to ' support the actions:or surveillances required by theiTSs. Since the table would be relocated to the TRM, appropriate notations will be added to the TRM: to clarify that prior NRC aoproval of changes to the specimen' withdrawal schedule is required. Additionally, _ the capsule numbers, vessel'._ locations, lead factors, and' withdrawal ' schedule are described in Updated i Safety Analysis Report--(USAR)'Section'5.3.1~.6.; The deletion'and j subsequent relocation of this information from the~TSs complies with the p guidance contained in GL 91-01. The staff finds the proposed change'. .I acceptable. _(15) The licensee proposes to revise LCO 3.6.1.3.b to delete the' reference to Table 3.6.4-1 for appropriate test pressures. for Type:B and Type C tests. With:the removal of this table. which required 7.6 psig, the licensee, . proposes to modify'the LCO to add a test pressure value of 7.6 psig. This proposed change to add the pressure in the LCO will maintain the~ requirements suitable for the facility in' the TSs and will allow lists to. be relocated. This test pressure is currently stated in the SRs and therefore there is - no technical change to the LCO. The staff finds the proposed changes acceptable.

~ ;y zg = [ 7[ .l i +( -7. -l 1 f(16) LC0;3;6.1.3.d,' ACTION Statement (with)-3:6;1.3.d, and ACTION Statement L b, --(restore): 3.6.1.3.d are proposed to be revised to delete the' references - 1 to Table 3.6.1.3-1 " Annulus Bypass Leakage Paths"L Table 3.6.1.3-1. is ;. ~ being deleted from the TSs and relocated to the TRM (as discussed below). c

This;is an administrative change to support the deletion of.

' Table 3.6.1.3-1.. With the proposed revisions, the requirements apply to all primary containment. penetrations that are annulus bypass leakage. . paths, rather_ than those specified in the table. The. staff. finds the . proposed changes acceptable. -(17) LCO 3.6.1.3.e, ACTION (with) Statement 3.6.1.3.e, and ACTION (restore)-- Statement 3.6.1.3.e are proposed to be revised to delete the references to Table 3.6.4-1, " Containment and Drywell Isolation Valves". ~ The referenced Table 3.6.4-1 is being deleted from the TSs and relocated-to the TRM (as discussed below). This is an administrative change reflecting the deletion of Table 3.6.4-1.. With the proposed revisions, the. requirements apply to - all valves that are secondary containment bypass leakage paths and are equipped with penetration valve leakage control system (PVLCS), rather than those valves'specified in the table. The staff finds the proposed-changes acceptable. -(18) LCO 3.6.I'.3.f, ACTION (with) Statement 3.6.1.3.f, ACTION (restore) Statement 3.6.1.3.f, SR 4.6.1.3.d.4, SR~4.6.1.3.1, and Footnote (*) to SR 4 4.6.1.3.d are proposed to be revised to delete the references to-

. )

Table 3.6.4-1, " Containment and Drywell Isolation Valves". - The~- referenced Table 3.6.4-1 is being deleted from the TSs.and relocated to - the TRM (as discussed below). This is an administrative change reflecting the deletion of. Table 3.6.4-1. With the proposed revisions, the requirements apply to all primary containment' isolation valves in-hydrostatically tested lines which penetrate containment, rather than those specified in the. table. The staff finds the proposed changes acceptable. (19) Delete Footnote (**) to SR 4.6.1.3.d and SR.4.6.1.3.f. This footnote provides an extension of the test interval until the first refueling outage, which occurred in 1987, and is'no longer necessary. The proposed change is editorial in nature and does not result in a technical ~ change to the current requirements. The staff finds the proposed change acceptable. (20) Delete Footnote (*) to SR 4.6.1.3.1. This footnote provides an extension of the test interval until the first I refueling outage, which occurred in 1987, and is no longer necessary. The proposed change is editorial in nature and does not result in a technical change to the current requirements. The staff finds the proposed change acceptable.

m, u, x 'h

2. W%,h, 0 g i

op a y fl@ ', l P';,.:1'.__ _ -8' ~ 1 1NS; ' ~ j 4 J(21) Stable 3.6.1.3-1:isiproposed to be deleted from.the. TSs' and relocated to ~ (, ithe;TRM. ATable:3.6.1.3-1; currently denotes = annulus bypass' leakage; paths =

associated,withl Specification 3/4.6.1.3 " Primary Containment-Leakage".:

The, table also specifies leakage' limits forthe fuel building and m . auxiliary building. : The combined leakage. limit is specifled in- ^ -LCO 3.6.I'.3.d 'as 13,500 cc/hr for both the fuel: building and auxiliary ' 7g, building. m's -With the~ proposed revisions to TS 3 6.1.3,(see above), the requirements-j for annulus bypass' leakage ~ paths'are stated in general termsLand thev details in' Table.3.6.1.3-1 are;nott necessary to support the actions or + surveillances required by the TSs. The'information_being relocated.to; i ? -the TRM is controlled and subsequent changes will be1 reviewed:in si accordance with the change control program described in' Specification ~6.5.2.. The relocation of the information in the table complies with the; 1 guidance. contained in GL 91-08. _The staff finds the proposed change: 1 acceptable. -(22) SR'4.6.1.3.1 is proposed to be revised to include part of note (j) from ' l Table 3.6.4-1. - This addition is to clarify the existing SR since:the-l reference-to Table 3.6.4-1 was removed '(as discussed above). ; Although,. this statement-is a. duplication of the 10 CFR Part 50, Appendix'J ' q requirements, it'is proposed to be added to SR 4.6.1.3.1 as follows for.- i clarity. j l "This leakage _ may be excluded when ' determining the combined leakage l rate, 0.60.La." ] This is an administrative change to support deletion of Table' 3.6.4-l' ' The staff finds the proposed: changes acceptable. ]o d (23) LCO 3.6.4 is proposed to be revised to delete the' reference to Table 3.6.4-1 " Containment:and Drywell; Isolation Valves" and thel reference to the isolation times: shown in Table 3.6.4-1. 'In. addition, j the proposed revision makes the associated requirements applicable to' 1 each containment and drywell isolation valve, rather than only those: specified in the table. The table is being deleted from the>TS and l relocated to the TRM (as discussed below). l a With the proposed revisions, the requirements apply to containment and j drywell isolation valves in general. and the information from

1 Table 3.6.4-1 is not necessary to support the actions, or SR by the TSs.

j The'information being relocated to the TRM is contro11edLand subsequent ochanges will be reviewed in accordance with.the-change control program-i described in Specification 6.5.2. -The relocation of:theninformation-in q the table complies with the guidance contained in GL 91-08. :The staff finds the proposed change acceptable. I (24) ACTION Statement 3.6.4, SR 4.6.4.1, SR 4.6.4.2, and SR 4.6.4.3 are j proposed to be revised to delete the references to Table 3.6.4-1 " Containment and-Drywell Isolation Valves". The referenced Table.3.6.4 j is being deleted from the TSs and relocated to the TRM (as discussed 1 below). ] u

  • i t....

.g. This is an administrative change to support the deletion of Table 3.6.4-1. With the proposed revision, the requirements apply to primary containment and drywell isolatis1 valves in general, rather than only to those valves specified in the table. The staff finds the proposed changes acceptable. (25) SR 4.6.4.1 is proposed to be revised to delete the word "specified" since, with the deletion of Table 3.6.4-1 (Containment and Drywell Isolation Valves), the isolation times for automatic primary containment isolation valves (PCIVs) are no longer specified in the TS. Table 3.6.4-1 is being deleted from the TSs and relocated to the TRM (as discussed below). This is an editorial change to support the deletion of Table 3.6.4-1 and the revision discussed above. The staff finds the proposed changes acceptable. (26) Table 3.6.4-1 is proposed to be deleted from the TSs and relocated to the TRM. Table 3.6.4-1 <urrently danotes drywell and containment isolation valves associated with Specification 3/4.3.2 (Isolation Actuation Instrumentation), Specification 3/4.6.1.3 (Primary Containment Leakage) and Specification 3/4.6.4 (Primary Containment and Drywell Isolation Valves). The table also includes a list of associated valve numbers, penetration numbers, valve groups, maximum isolation times, and containment penetrations which constitute secondary contaitiment bypass leakage paths. The footnotes associated with Table 3.6.4-1 are also proposed to be relocated to the TRM. Footnote (j) is the only footnote to Table 3.6.4-1 being retained, in part (as discussed above). With the proposed changes to TSs 3.3.2, 3.6.1, and 3.6.4 that generalize the requirements in each TS, the information it the table is not necessary to support the actions or the survei,iances required by the TSs. The information contained in the table is also described in USAR Table 6.2-40 and will be in the TRM. The information being relocated to the TRM will be controlled and subsequent changes will be reviewed in accordance with the change control program described in TS 6.5.2. The deletion and relocation of Table 3.6.4-1 complies with the guidance contained in GL 91-08. The staff finds the proposed changes acceptable. (27) Delete Footnote (#) associated with SR 4.6.4.2. This footnote provides an extension of-the test interval until the first refueling outage, which occurred in 1987, and is no_ longer necessary. The proposed change is editorial in nature and does'not result in a technical change to the current requirements. The staff finds the proposed change acceptable. (28) The proposed change revises SR 4.6.4.1 and SR 4.6.4.2 to clarify that the various requirements relate to " primary containment or drywell" isolation valves. Inse-ting the word " primary containment or drywell" in the SRs . clarifies the SRs and makes the wording consistent with that of the LCO and ACTION Statements.

r D'g,.,, t i 1* l These changes are provided for clarification only and do not result in any technical change as these requirements have always been understood to relate to " primary containment or drywell" isolation valves. The staff l' finds the proposed change acceptable. l (29) LCO 3.6.5.3, ACTION Statement 3.6.5.3, and SR 4.6.5.3 are proposed to be j revised to delete the references to Table 3.6.5.3-1 (Secondary 1 Containment Ventilation System Automatic Isolation Dampers) and to delete l the reference to isolation times. Table 3.6.5.3-1 denotes secondary l containment ventilation system automatic isolation damper functions, i maximum isolation times, damper isolation groups and applicable operational conditions. The table is being deleted from the TSs and l relocated to the TRM (as discussed below). The licensee had originally l proposed to include the word " required" in front of the phrase " secondary containment ventilation system isolation dampers." The word " required" was also proposed in other technical specifications as a means to I preserve the specified modes in the TSs rather than in the table to be relocated. Since this language was not specific in several proposed TS changes, the licensee agreed to remove all the phrases " required." However, in the November 10, 1994, letter, the license overlooked this one TS. In the February 8,1995, letter, the use of the word " required" is proposed to be removed from this TS. This applies to the LCO, Action Statement, and SR where the word " required" was initially proposed. See item (30) and (31) below. The details in this table are for information only except for the listing I of the applicable operational conditions for the associated dampers (as { discussed below). Since dampers may not be required to be OPERABLE in each of the operational conditions listed in the proposed change to the APPLICABILITY statement, the words in the LCO, ACTION Statement, and Surveillance Requirement have been revised. With this proposed change, the list of secondary containment ventilation system automatic isolation dampers is not necessary to support the actions or surveillances required by the TSs. The proposed changes are consistent with the guidance in GL 91-08. The staff finds the proposed changes acceptable. (30) The APPLICABILITY statement for LC0 3.6.5.3 is proposed to be revised to replace the reference to Table 3.6.5.3-1 (Secondary Containment Ventilation System Automatic Isolation Dampers) with OPERATIONAL CONDITIONS 1, 2, 3, and H. Table 3.6.5.3-1 denotes secondary containment ventilation system automatic isolation damper functions, maximum isolation times, damper isolation groups and applicable operational conditio The table is being deleted from the TSs and relocated to the TRM ss discussed below). The APPLICABILITY statement was proposed to be changed concurrent with the change adding the word " required", as noted above. However, this use of the word " required" has been withdrawn by the licensee; see item (29) above. In reviewing the table to be removed, it was determined that applicability statements or conditions were included for previous convenience. In keepir.g all applicability statements in the TS with relocation of table information to the TRM, certain fuel building damper statements needed to be

l. t i y 8 3 a f g*k he j v 1 pp

g 4

_ 11 ,j ,s m q addressed.- The' staff has corrected the' proposed statements consistent: d n with the guidance of GL'91-08 and changed the statement to read: - 1 q - OPERATING CONDITIONS;-1, 2, and'3

I

- FOR FUEL BUILDING DAMPERS; OPERATING' CONDITIONS 1, 2,= 3 AND H. c. a This assures the dampers needed for fuel. movement will be~ 0perable' 1 + fwhenever fuel is' moved and that the requirements for operability havei been adequately moved _ from the table to the LCO. 4The:11censee's. language j was inadequate-and would-have required the dampers operable:in~ all modes: i which is beyond.the requirements.of the original TS wording :and the'. j 0-purpose of GL 91-08. The licensee ' agrees to this clarification of their-1 proposal. 1 With the proposed incorporation of the operational conditions into' the APPLICABILITY statement,' the details in Table 3.6.5.3-1 are not necessary. j to support the actions.or the surveillances required by the -TSs. - The U proposed change is consistent with the guidance provided in GL 91-08 and? j does not result in a technical change to the TSs. -The staff finds thel 1 proposed changes ' acceptable. j ~(31) SR 4.6.5.3.a-is proposed to be revised to delete the~ word "specified"' since, with the deletion of Table 3.6.5.3-l'" Secondary Containment-Ventilation System Automaticilsolation Dampers",. the isolation.. times for 4 a automatic dampers are no longer specified. Table 3.6.5.3-1 is being-j deleted from the;Tss and relocated to the TRM (as discussed below). The Li r use of the word " required" was removed by the licensee; see item (29) tj above. ] This is an editorial change associated with the relocation of. 1 Table 3.6.5.3-1 to the TRM. The staff finds the proposed change acceptable, j o (32)' Table 3.6.5.3-1.and' associated footnotes are proposcJ to be deleted from 7 ~ the Tss and relocated to the TRM. Table 3.6.5.3-1 currently denotes secondary containment ventilation system automatic-isolation dampers. The table also denotes a list of damper functions,' maximum isolation L times,. damper group numbers (associated with Specification 3/4.3.2, " Isolation Actuation-Instrumentation") and applicable operational conditions for the associated dampers.. With the proposed changes to TS 3/4.6.5.3, the requirementsiapply in general to each secondary containment. ventilation system automatic.

isolation damper. The information being relocated to the TRM is controlled and-subsequent changes will be reviewed in accordance with the change control program described in Specification.G.5.2. As a result, the deletion' and subsequent relocation of this information from the TSs'
~

complies with the guidance' contained in GL 91-08. The proposed changes are acceptable to the staff. i i s

5 5 %. f, i E~ I~ 7"" } l ~ ~~ " ex x + a @Myg[{ x n ~ 'j

l
  • W 3[_,

r 4 T ~.. 2 l ~ i ~ ' L(33) Delete Footnote.(m) associated with SRl4.6.5.3.b.. M m iThis footnote provides an extension of the test interval uhtil theifirst ~ %e, ' ~ refueling. outage,,which occurred'in-1987.=;The footnote action has been Lcompleted and the footnote is no longer necessary.. The proposed. change. .is. editorial in; nature and'does not result <in aTtechnical changeito:the- ' q c ( i j,3 g current requirements. The' staff finds the proposed change acceptable. g(34) SR 4.6.5.3.b is being revised.to clarify that the. containment: isolation? e n x 1 g' test signal;1dentified;in this surveillance is a secondary containment' isolation signal (versus primary containment isolation signal..forJ texample)3and that the isolation dampers to be verified are: secondary i. l' containment. automatic' isolation dampers. j This proposed change provides clarification only,Ldoes not alter the intent of the surveillance, and does not result in 'any technical change l l to the operability or. testing requirements. The staff finds the: proposed:

l

. change acceptabic. q w (35).LCO 3.8.4.1,. ACTION Statement 3.8.4.1, and SR 4.8.4.1 are proposed to:bef revised to delete the references to Table 3.8.4.1-1 (Primary Containment" Penetration Conductor Overcurrent Protection Devices). The referenced Table 3.8.4.1-1 is being ' deleted from the Tss and relocated to'the TRM _ (as discussed below). 1 The LCO is~also being revised to state that the. scope of this TS includes-each of the primary and backup overcurrent' protective devices associated:

j with each primary containment electrical penetration ~ circuit, but i

excludes those circuits for which credible fault ~ currents would not i~ exceed-the electrical penetrations' design ratings. This statement' t reflects the~ basis for which.the contents ofsthe table were origina11yL developed and does not constitute a technical. change.nThis revision to the LCO is also as recommended in GL 91-08. The staff. finds-the.' proposed changes acceptable. ll a (36) Table 3.8.4.1-1 is proposed to.be deleted from the TSs and relocated.to

j the TRM. Table 3.8.4.1-1 currently denotes primary containment ~

penetration conductor overcurrent protection devices for 4.16 kV circuit 1 breakers, 120/140 VAC molded case circuit breakers,. 480 VAC molded case ij cirr:uit breakers, and air. circuit breakers. For each type of circuit-1 ' breaker, the table denotes the equipment or device; number and location of 7 each circuit breaker. With the proposed revisions to TS 3/4.8.1, the requirements' apply in e general to the primary and backup overcurrent protection' device associated with each primary containment electrica1' penetration circuit, excluding those circuits for which credible fault currents would not 6 exceed the electrical penetration's design rating. The information in Table 3.8.4.1-1 is being relocated to the TRM. This information is-controlled and subsequent changes will be reviewed in.accordance with the change control program described in Specification 6.5.2. In. addition, ( USAR Section 8.3.1.4.2 addresses the requirements for overcurrent l, ~ to -- ip- -g us. --r s. ,m.* ,,wv.e my ,-w.mr,e.,, ,.....,e p.-%..i.-- .,.-..--.,-.-,.e_,s.m m.~. .-i+.-.~.--.. v. u ..,.--.,v

g g q W = + t ,Q l j 71 m eo:- 13 -- " ~ ' protection' of the containment electrical penetratio'ns. As a result,= the li deletion and subsequent relocation of this information from the TSs - complies with the guidance contained.in GL 91-08. - The staff finds the proposed chenges acceptable. j n '(37);LCOl3.8.4.2'and ACTION. Statement 3.8.4.2'are' proposed to be revised to-l delete, the references to Table 3.8.4.2-1 (Other 0vercurrent Protective. E Devices)..-The referenced Table'3.8.4.2-1-is.being deleted from the TSs 'and relocated to the TRM (as discussed below). i ,i This LC0 is also being revised to state that the scope of the TS includes? i f' each primary overcurrent protection device. for the Main Control Room safety-related lighting and the primary and : secondary RPS' Alternate - . Source of Power. This statement reflects the basis for which the contents of.the table were originally developed and does not. constitute a-j ' technical change. The staff finds the proposed changes acceptable. { t (38) Table 3.8.4.2-1 is proposed to be deleted from the TSs' and relocatedito j the TRM. Table 3.8.4.2-1 currently denotes other overcurrent protective-devices for Main. Control Room lighting and Reactor Protection System! 1 alternate source of power. For each type of overcurrent protective ' device, the table denotes the equipment or device number. With the proposed changes to TS 3/4.8.4.2, the information in~ i Table 3.8.4.2-1 is being relocated to the TRM. This'information is... a controlled and subsequent changes will be reviewed in accordance with the d change control' program described in Specification 6.5.2. As a' result,. j t the deletion and subsequent-relocation of.this information from the TSs. i complies with the. guidance contained in GL 91-08. With the proposed-change, the requirements apply to each required overcurrent protection-i device and the information in the table is not necessary to support the '~3 actions or-surveillances required by the TSs. The staff finds.the proposed changes: acceptable. I (39) LCO 3.8.4.4, ACTION Statement 3.8.4.4, and SR 4.8.4.4 are proposed:to be. revised to delete' the references to the component list currently included :

{

in th3 LCO. The component list denotes the equipment identification number, device number, and location of A.C. circuits inside' containment'. The component list is being relocated to the TRM and is controlled-and l subsequent changes will be reviewed in accordance with the change control program described in Specification 6.5.2. y -The LCO is also being revised to state that each 480V and 240/120V A.C., circuit inside containment for the containment Building HVAC, Drywell-Cooling HVAC, RWCU, Inclined Fuel. Transfer Tube, and Reactor Building q Main Holst Systems without redundant penetration protection shall. be de-energized..This' statement reflects the basis for which the contents of-1 the table were originally developed and does not constitute a technical change. The deletion and subsequent relocation of this information from'~- 1 the TS complies with the guidance contained in GL 91-08. The staff finds. the proposed changes acceptable. 1 I l 1 .-,, s, . ~ u

% &J N s ^ -.14 - . b-

(40) Revisions to TS'6.5.2, " Technical Review and Control," _are proposed to.

' add a reference'to the Technical Requirements Manual _ and.to require that

implementing procedures and changes to the manual be~ approved ~ in accordance with TS 6.5.2.1 and that records of these activities be-kept.

L .The staff finds the proposed changes acceptablei n (41)'AL-revision t'o TS 6.8.1, " Procedures and Programs," is proposed to add the-Technical? Requirements Manual to the list of documents-subject to the s controls of TS 6.8.1. The staff finds the: proposed changes acceptable. The staff's review of the proposed changes determined that-the relocation > of Tables 3.4.3.2-1, 3.4.3.2-2, 3.6.1.3-1, 3.6.4-l', 3.6.5.3-1, 3.8.4.1-1, and 3.8.4.1-2 doesinot eliminate the: requirements for the-licensee to ensure that associated components are: capable of: performing their safety? function. Although the' tables listed above are relocated from the technical specifications to the Technicc1' Requirements-Manual, the-licensee must evaluate any changes to the components listed in' the tables-in accordance with 10 CFR 50.59. Should the licensee's evaluation = 1 c-conclude that.an unresolved safety question.f s involved,' due:to either (1):an increase in the probability or consequencesLof accidents:or malfunctions of equipment important to safety,- (2) the creation of a - possibility for an' accident or malfunction of a different. type than any; evaluated previously,.or (3) a reduction in the~ margin of safety, NRC approval. and a license amendment would be required prior to -implementation of the change..NRC inspection and.' enforcement' programs: also enable tha staff to monitor facility changes and licensee adherence to commitments and to take remedial action that:may be appropriate.. The staff's review concluded that'10 CFR 50.36 does not require ~ ~ Tables.3.4.3.2-1, 3.4.3.2-2, 3.6.1.3-1, 3.6.4-1, 3.6.5.3-1, 3.8.4.1-1, or 3.8.4.1-2 to be retained'in the TSs. Requirements related to the ^ operability,' applicability, and surveillance requirements,1 including F performance of testing to ensure operability of the listed components;is retained due to the components' importance'in mitigating the consequences of an accident. However, the staff determined,that the inclusion ofl these tables are an operational details related to the licensee'sLsafety analyses which are adequately controlled by the requirements'.of-10 CFR-L 50.59. Therefore, the continued processing of license amendments related to revisions to these tables, where the revisions.to those requirements. do not involve an unreviewed safety question under 10 CFR:50.59, wouldl afford no significant benefit with regard to protecting the public health-and safety. e The staff has concluded, therefore, that relocation of Tables 3.4.3.2-1,. 3.4.3.2-2, 3.6.1.3-1, 3.6.4-1, 3.6.5.3-1, 3.8.4.1-1, and 3.8.4.1-2 is acceptable because (1) their inclusion in the TSs is not specifically required by 10 CFR 50.36 or other regulations, (2) the tables 'have been relocated to the Technical Review Manual, are adequately controlled by TS 6.5.2 and 10 CFR 50.59, (3) their inclusion in the TSs is not required

n_ l-6 # q (- 0: - to avert an'immediate threat to the public health and safety, and (4) changes that are. deemed to' involve an unreviewed safety question, will require prior NRC approval in accordance with 10 CFR 50.59(c).

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted-area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant changes in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative eccupational 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 (59 FR 65815). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment. t

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) 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. Principle Contributors: E. Baker, NRR R. Schaaf, NRR i Date:. March 8, 1995 i 5 l -}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20081B785&oldid=4377377"