RBG-30778, Forwards Rev to 860829 Application for Amend to License NPF-47 Re Suppression Pool Pumpback Sys Operability

Forwards Rev to 860829 Application for Amend to License NPF-47 Re Suppression Pool Pumpback Sys Operability

ML20246H544
Person / Time
Site:	River Bend
Issue date:	05/02/1989
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20246H549	List: ML20246H553 RBG-30778, Forwards Rev to 860829 Application for Amend to License NPF-47 Re Suppression Pool Pumpback Sys Operability
References
RBG-30778, NUDOCS 8905160129
Download: ML20246H544 (5)

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s GULF STATES UTILITIES COMPANY ;i AfVER BEND STATION POST OFFICE BOX 220 ST FRANCISVILLE, LOutslANA 70776 AREA CODE 604 63S-6094 346 8661 May 2,1989 RBG- 30778 File Nos. G9.5, G9.42 U.'S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. .20555 Gentlemen:

River Bend Station - Unit 1 Docket No. 50-458 As a result of discussions with the .NRC Staff, Gulf States

-' Utilities (GSU) Company hereby files-a revision to our amendment dated , August. 29, 1986 (RBG-24285) concerning suppression pool pumpback. system operability. ,The attachment to this letter >

includes proposed revisions and justifications for this change.

Sincerel ,

W

1. J. C. Deddens Senior Vice-President g g River Bend Nuclear Group JCD/fB/L / /ch Attachment l cc: U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Mr. Walt A. Paulson, Project Manager U. S. Nuclear Regulatory Commisison Document Control Desk Washington, DC 20555 NRC. Resident Inspector P. O. Box 1051 St. Francisville, LA 70775 l

Mr. William H. Spell, Administrator Nuclear Energy Division Lousiana Dept. of Environmental Quality 0g P. O. Box 14690 Baton Rouge, LA 70898 / -[{(

8905160129 890502 PDR ADOCK 05000458 P PDC 1

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-UNITED STATES OF AMERICA NUCLEAR' REGULATORY COMMISSION STATE OF' LOUISIANA )'

PARISH OF WEST FELICIANA )

Docket No. 50-458 In-the Matter of )

GULF STATES UTILITIES COMPANY )

(River Bend Station - Unit 1)

AFFIDAVIT J. C. Deddens, being duly sworn, states that.he is a

' Senior Vice President of Gulf' States Utilities Company; that he is authorized on the'part of 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, information and belief.

!// J// W J. C/ Veddeh's Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this' d day of 2f) tlc 4 , 19 [ 7 . My Commission expires with Life.

v Ofauds Claudia F. Hurst 1/Jwtat Notary Public in and for l West Feliciana Parish, Louisiana 1-

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ATTACHMENT j

GULF STATES UTILITIES COMPANY-RIVER BEND STATION-DOCKET 50-458/ LICENSE NO. NPF-47 l SUPPRESSION P00L (86-018 Rev. 1)

LICENSING DOCUMENT INVOLVED: OPERATING LICENSE NPF-47 TECHNICAL SPECIFICATIONS ITEMS: Specification 3/4.5.3 PAGES: 3/4 5-8 3/4 5-9 REASON FOR REQUEST This proposed change is being requested in accordance with'10CFR50.90 to-revise Gulf States Utilities Co. (GSU) proposed change submitted August. 29, 1986 (RBG-24285) to address NRC staff concerns with suppression pool pump back system (SPPS) operability.. This proposed change revises the limiting condition for operation (LCO) by increasing the minimum subsystems required to be operable from one to two and including appropriate ACTION statements.

DISCUSSION During the review of the original submittal (RBG-24285), the staff identified

a. concern with the time.between surveillance, 92 days, when only one SPPS subsystem is operable. To address this concern GSU proposed' to add functional testing to the ' ACTION statement "c", each 31 days, when.a SPPS subsystem is

- i noperable~. A functional test is proposed. in lieu of a full (92 day) surveillance test because of the difficulty in performing the full test and since=the pumps'are used in normal plant operation, loss of the remaining-operable subsystem would be readily detectable. Therefore, the plant staff will have an additional awareness of the systems condition.

GSU also requests relief from the provisions of Specification 3.0.4 to allow startup and operation with one SPPS subsystem inoperable when the suppression pool is required. As discussed in Safety Analysis Report (SAR) section 9.3.~7, the SPPS is designed to control post-LOCA emergency core cooling system (ECCS) leakage in the auxiliary building crescent area, el. 70', by returning this water to the suppression pool. During normal operation the system pumps floor and equipment drainage to the radwaste building, following a LOCA the system is manually realigned to the suppression pool. Leakage from the ECCS piping in this area would come from two portions of the piping. The first is between the containment and the outboard containment isolation valve and the second is between the isolation valve and crescent room boundary. In the first area the piping is designed in accordance with ASME Section III, Subarticle NE-1120 and also complies with Standard Review Plan section 3.6.2 and Branch Technical position MEB-3-1. As discussed in RBS SAR section 3.6.2.1.5.2A and B. .The additional design requirements are in support of the assumption of no postulated line failures in these portions of the ECCS piping. For postulated Page 1 of 3 1

leaks between the isolation valve and the crescent room boundary. The leakage l can be stopped through the closure of the isolation valve. Leakage from the containment boundary to the outboard isolation valve has been conservatively assumed to be 50 gpm. This leakage rate would require an excess of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to lower the suppression pool to the minimum level for ECCS pump operability.

In addition, each of the ECCS equipment rooms are located in separate water tight cubicles and therefore, the failure of the SPPS will not inhibit the primary success path of the safety analysis. In the event of a failure of a watertight cubicle, only one subsystem is necessary to tuoport plant operation; therefore, startup or entry into an operational condition can be made with one subsystem of SPPS inoperable.

A review of this request against criteria 3 of the Interim Policy Statement on technical specification improvements and the RBS safety analysis indicates this system is not required as a primary success path because failure of the SPPS alone does not result in a failure of the suppression pool or ECCS.

Therefore, the level of safety assumed in the safety analysis will be maintainad if mode changes are allowed with one subsystem inoperable.

Contine performance of minimum system requirements are required by ACTION c.1 me c.2. GSU, there fore, requests mode change restrictions of Specification 3.0.4 be removed for this system. This position is supported by criteria provided in Generic Letter 87-09 where mode changes are allowed if continued operation for an unlimited period of time is permitted by the ACTION requirements.

In concert with the above, changes to the bases are included to address the additional testing and removing the stated pump capability (65 gpm) because this flow rate is not required by the license or system design.

NO SIGNIFICANT HAZARDS CONSIDERATION The following discussions are provided to the NRC staff in support of "No Significant Hazards" per 10CFR50.92.

The revision to the action requirements will not increase the probability or consequences of an accident previously evaluated or create the possibility of a new or different event because the system design and operation remains consistent with that provided in the Safety Analysis Report, therefore, plant response remains as originally evaluated.

The relief from the provisions of Specification 3.0.4 will not reduce the level of safety because one system is still required and the operability of the ECCS equipment is not effected by leakage in the crescent area. Because of the watertight ECCS cubicals, this evaluation has shown with one SPPS subsystem operable the plant response to a single failure will not result in a primary success path, as analyzed in the safety analysis report, being inhibited. The request to allow startup and changes in the operational condition with one subsystem operable also supports the basis of the Technical Specification.

The change will not reduce any identified margin of safety because the functional testing will increase the plant staff awareness of the systems ability to perform as described in the Safety Analysis Report. Because the pumps are used during normal plant operation, the knowledge of the loss of the remaining operable subsystem will be readily available.

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In conclusion,:the proposeJ operating change will not increase the possibility or the consequences of a previously evaluated event'and will not create a new or different kind of accident from iny previously evaluated. Also, the results of this _ request are within all acceptable criteria will respect to system components andi design requirements. The ability' to perform as described' in the USAR is maintained and therefore, the proposed change does not involve a significant reduction in the margin of safety. The ref.m. GSU proposes that no significant' hazards are involved.

REVISED LICENSE CONDITION AND TECHNICAL SPECIFICATION:-

-The requested revisions are provided in the Enclosure..

SCHEDULE FOR ATTAINING COMPLIANCE:

As indicated .above, River Bend Station is currently in compliance with the applicable Technica? . Specification and license condition.

NOTIFICATION OF STATE PERSONNEL:

A copy of the. amendment application has been provided to the State of Louisiana, Department of Environmental Quality-Nuclear Energy Division.

.ENVIR0fmENTAL IMPACT APPRAISAL:

Gulf States Utilities Company (GSU) has reviewed' the proposed license amendment against .the criteria of 10CFR51.22 for environmental considerations.

As shown above, the ' proposed changes do not involve'a significant hazards consideration, nor increase the types and amounts of effluents that may be released ' offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, GSU concludes that the proposed changes meet the criteria given in_ 10CFR51.22(c)'9) for a i categorical exclusion from- the requirement for - an Environmental Impact

-Statement..

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