RBG-38-025, Informs of Error Identified in Bases During Implementation of Amend 64 to Ts.Error Was Inclusion of Leak Detection Subsys as Part of List of Required Sys/Subsys in Bases for TS 3.8.1.1 Action E.Draft of New Bases Encl

Informs of Error Identified in Bases During Implementation of Amend 64 to Ts.Error Was Inclusion of Leak Detection Subsys as Part of List of Required Sys/Subsys in Bases for TS 3.8.1.1 Action E.Draft of New Bases Encl

ML20127M005
Person / Time
Site:	River Bend
Issue date:	01/19/1993
From:	Odell W GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20127M010	List: ML20127M015 RBG-38-025, Informs of Error Identified in Bases During Implementation of Amend 64 to Ts.Error Was Inclusion of Leak Detection Subsys as Part of List of Required Sys/Subsys in Bases for TS 3.8.1.1 Action E.Draft of New Bases Encl
References
RBG-38-025, RBG-38-25, NUDOCS 9301280079
Download: ML20127M005 (5)

Text

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- GULF STA TES wo wame UTILITIES enm vn no COMPANY e amenan uus su m 29e AP4 A ^O!.4 4 W A E $144 :ML M51 January .10 ,1993 File Nos. G9.5, G9.42 RBG. n ,025 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC ~20555 Gentlemen River Bend Station - Unit 1 Docket No. 50-458 During the implementation of Amendment 64 to the River Bend Station Technical Specifications (TS), Gulf States Utilities Company (GSU) identified an error in the BASES, as they were submitted to and approved by the NRC. -This request was submitted in 1989 with the final approval of Amendment 64 coming in 1992.

The error was the inclusion of leak detection subsystems as part of the list of required systems / subsystems in the BASES for TS 3.8.1.1 ACTION 'e'.

The NRC project manager for River Bend Station, Mr Ed Baker, was contacted l on December 18, 1992 to be made aware of this problem and to discuss the -

necessary corrective action. GSU understands that the corrective action for similar issues has been to submit the correction with explanation to the NRC. In the restructured standard technical specifications this problem would be under the -

contml of the utility. After reviewing this issue Mr. Baker agreed a revision to the BASES which does not change the licensing basis, intent of the specification or amendment, can be changed by the licensee with a submittal to the NRC to document the reasons and change. GSU has detennined this change will ~not change the licensing basis or intent of the speci0 cation, and therefom should not restrict plant operations as discussed in Attachment I to this htter. Attachment 2 pmvides a draft of the new BASES.

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93o1200079 930119

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.'p,P DR ADOCK 05000458.

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t If you have any questions please contact Mr. L L. Dietrich of my staff at (504)381-4866.

Sincerel Q;h()

W.11. Odell Manager - Oversight River Bend Nuclear Group I dr /Bhk pj Attachments (1), (2) cc: U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 .

Mr. E. T. Baker U.S. Nuclear Regulatory Commission i1555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 -

Depanment of Environmental Quality Radiation Protection Division P.O. Box 82135 Baton Rouge, LA 70884-2135

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ATTACIIMENT 1

References:

GSU Submittal dated May 2,1989 (RBG-30780) Attachments 1 and 2 NRC SER dated September 29,1992 (RBC-42813)

RG-1.45 dated May 1973 SRP 5.2.5 SAR 5.2.5 SER 5.2.5 Discussion:

On May 2,1989 GSU submitted an amendment request to revise the emergency diesel generator (EDG) action requirements contained in Technical Specification 3.8.1.1. The NRC approved this request on September 29,1992 as Amendment

64. This change was submitted by GSU as a lead plant to implement concepts included in the improved technical specir:catior.s (ITS). In this submittal, one '

issue was the inclusion of specific criteria in the B/.:'ES for the definition of

" required" contained in ACTION 'e' to identify which systems need to be checked to allow the use of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AOT prior to entering the shutdown statement. In addition to the discussion in the submittal of the criteria used, a list identifying the expected systems was included in the revised BASES as submitted.

The criteria as discussed in Attachment I of the submittal , pp 6-8,_in summary are; the system (s) must be necessary to respond to a loss-ef-offsite power event,-

the systems must be necessary to respond to a LOCA event, the system (s) must be necessary for the attainment of safe shutdown and maintenance of this condition, and the loss of either Division I or II EDG will not result in the complete loss L of the safety function of critical safety systems. This includes systems which are supplied by only one EDG ( eg., some RG-J.97 systems) which was addressed by inclusion of the word redundant in the ACTION. In addition, those systems which have no TS operability requirements ( eg.,

the reactor building polar crane) were excluded because credit is not taken

! in the SAR for this equipment.

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As a result of further reviews conducted when implementing this change, GSU has identified an error in this list. Item 2 is " two leak detection subsystems per Technical Specification 3.4.3.1"; this item can not comply lwith the redundant power criteria.

The leak detection system is described in Section 5.2.5 of the Updated Safety Analysis Report (SAR) and was found in compliance with SRP Section 5.2.5 and RG-1.45 and documented in SER Section 5.2.5. In the evaluation, the NRC r.oted the gaseous and paniculate radiation monitors are powered by 1B sources to ensure functioning following an SSE. No other requirement is identified to compel the design to include redundant instruments or IE power sources. In addition, the leak detection equipment is not necessary for the safe shutdown of the plant following a LOCA and/or a loss-of-offsite power, therefore this system should not have been included in the ' 2.

To resolve this problem GSU will remove item 2 of the list. TN NRC is requested to make the changes to the present BASES pages as shown in Attachment 2 to this !ctter and reissue them to GSU.

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A'ITACIIMENT 2 Correction to BASES Section 3.8.1.1 as attached 1