RBG-26395, Application for Amend to License NPF-47,revising License Condition 2.C.14,Attachment 5,Item 2,which Addresses Reg Guide 1.97 Mods.Affidavit Encl.Fee Paid

Application for Amend to License NPF-47,revising License Condition 2.C.14,Attachment 5,Item 2,which Addresses Reg Guide 1.97 Mods.Affidavit Encl.Fee Paid

ML20237H921
Person / Time
Site:	River Bend
Issue date:	08/05/1987
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 RBG-26395, NUDOCS 8708170415
Download: ML20237H921 (8)

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GULF rSTATES UTXLITIES COMPANY RNER DEND STATION POST OFFICE BOX 220' ST FRANCISVILLE,LOUISlANA 70775 AflE A CODE !O4 635 60944 346 8051 August 5, 1987 REG- 26395 File No. G9.5 U.S. Nuclear Regulatory Commission.

Document Control Desk Washington, D.C. 20555 Gentlemen:

River Bend Station - Unit 1 Docket No. 50-458 Gulf ~ States Utilities (GSU) Company hereby files an amendment to the River Bend Station Unit 1 Facility Operating License NPF-47, pursuant to 10CFR50.90. This application is filed to revise License Condition 2.C.14, Attachment 5, Item 2, which addresses Regulatory Guide 1.97 modifications. This revision to the license has been previously discussed with the NRC staff as documented in an NRC letter from S, M.

Stern- to J. C. Deddens dated April 23, 1987. The attachment to this letter includes proposed revisions to the license and justifications for this change.

Pursuant to 10CFR170.12, GSU has enclosed a check in the amount of one hundred fif ty dollars ($150.00) for the license amendment application fee. Your prompt attention to this application is appreciated.-

Sincerely,

.df W J. C. Deddens Sr. Vice-President River Bend Nuclear Group JCD/ DNL/ch Attachments I \

8708170415 370005 i Am O R

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IMI'HD SUSES CF MERICA 1

10CTAR PPnHATOIN OMESSICN STATE CF IIXIISIANA

• PARISH CF MEST FELICIANA

• In the Matter of

• Docket Nos. 50-458 GUT STMES ITTILITIES CIMPANY *

(River Bend Station, Unit 1)

AFFInnv1T J. C. Deddens, being duly sworn, states that he is a Senior Vice President of Gulf States Utilities Campany; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Cmmission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief, s s+

J. C. bxidehs Subscribed and sworn to before me, a Notary Public in and for the State and and Parish above named, this 8 day of />d v$f,19[

J s + / // dp

/yoan W. Middlebrooks 4/ Notary Public in and for West Feliciana Parish, Iouisiana My Comnission is for Life.

.- - - _ _ _ .___-_-__-__-_-_-_D

l cc: U.S. Nuclear Regulatory Commission j Region IV '

l- 611 Ryan Plaza Drive, Suite 1000 l

Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 Mr. William H. Spell, Administrator Nuclear Energy Division Louisiana Department of Environmental Quality P.O. Box 14690 Baton Rouge, LA 70898 l

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-ATTACHMENT GULF STATES UTILITIES COMPANY RIVER BEND STATION DOCKET 50-458/ LICENSE NO. NPF-47.

REGULATORY GUIDE 1.97 - Neutron Monitoring LICENSING DOCUMENT INVOLVED: Facility Operating License NPF-47 ITEM: License Condition 2.C.14 Emergency Response Capabilities

. Attachment 5, Item 2 j!

Reason For Request A change is b'eing requested in accordance with 10CFR50.90 to revise the implementation date of modifications to the River Bend -Station (RBS) neutron monitoring; system (NMS) as required in Attachment 5, Item 2 of the Facility Operating. License. This operating license. change- requests .{

that. the implementation date for neutron flux modifications be changed j from prior to startup following the first refueling outage to prior to 4 startup . following the second refueling outage (RF2).- Approval of this change vill allow operation with-the. current system through the second fuel cycle. The proposed change is required te allow start-up following the first refueling outage. currently scheduled to begin September 15, 1987. . In addition, the Boiling Water Reactor Owner's Group (BWROG) is developing a position 'for submittal 'o the . Staff rega: Jing implementation of ~ Category I neutron flux monitbra in accordance with Regulatory Guide (RG) 1.97.

Description Attachment 5, Item 2 to NPF-47 requires that GSU modify systems as required to meet RG 1.97 guidance before startup following the first refueling outage. An alternative allowed by this condition is to obtain NRC approval of an alternate design. The intent of RG 1.97 is to ensure that all light-water-cooled nuclear power plants are instrumented as necessary to measure certain prescribed variables and systems during and after an accident. RG 1.97 provides design and qualification requirements for this instrumentation.

On June 24, 1985 GSU provided a report to the NRC describing River Bend's justification of system compliance with the requirements of RG:1.97, Rev. 3.. On June 30, 1986 a Safety Evaluation Report (SER) was issued by the NRC. The conclusion of the SER was that the RBS design was acceptable, except for neutron flux instrumentation. Deletion of the seven parameters identified in Attachment 5, Item 2, other than neutron flux, is based on the NRC's acceptance of the RBS design. For neutron flux, the SER found the system to be acceptable for interim

operation until a conforming system is developed and installed. The SER recognized that design of a NMS which meets RG 1.97 was an . industry development item and therefore required that a nystem conforming to RG 1.97 be installed prior to start up following the first refueling outage. CSU has followed the industry development of this equipment and until~recently has not been able to evaluate newly developed equipment.

Currently, a Licensing Topical Report is being prepm ed to present the BWR Po.er's Group position on RG 1.97 requirements for NMS to the NRC.

Due to i.he status of this work, scheduling, procurement and installation of a' licensed system meeting the requirements of RG 1.97 is not possible during the first refueling outage.

The current RBS design employs Local Power Range Monitors (LPRMs),

Average Power Range Monitors (APRMs), Intermediate Range Monitors (IRMs) and Source Range Monitors (SRMs) for purposes of monitoring neutron flux. The instrumentation display _ ganges for the LPRM/APRM is from 1 t9 ted power, the IRMs at 5x10 to 10% rated power and SRMs at 10 120%

to 10 rg% rated power.Primary power is from preferred station 'offsite sources with a backup power supply from safety-related class 1E motor control centers which are used to power one or both reactor protection system (RPS) buses via switch control from the main control room in the event the normal RPS power supplies fail. Each instrument is displayed in the main control room via meters and is also available on the Safety Parameter Display System. The location of the monitors provide maximum sensitivity to control rod movement during the start-up period and provides optimum monitoring in intermediate and power ranges. A traversing incore probe system provides for periodic calibration of the neutron detectors.

The SRM and IRM detectors are stored below the core support plate during full power. operation and are able to trend flux levels even though they may not be inserted into the core. In addition to the NMS, safety relief valve (SRV) flow gives an indication of core power level.

Therefore, if all'NMS indication is lost the operator still has a Class 1E instrument system (SRV position) upon which to determine whether the core is shutdown. However, the large number of detectors (i.e.,

source-range monitors and intermediate-range monitors) that are driven into the core soon after shutdown makes it highly probable that one or more of the existing NMS detectors will be inserted.

In conclusion, it is CSU's position that the present NMS meets the safety intent of RG 1.97 as discussed in the RBS compliance report dated June 24, 1985. Interim operation with the currently installed system was accepted contingent upon industry development of an acceptable system design. Due to the incomplete status of work by the BWROG, resolution of this issue will not be complete in time to allow modifications during the first refueling outage. GSU will continue to work with the BWROG to resolve this issue prior to the end of River Bend l' Station's second refueling outage.

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No Significant Hazards Considerations As -discussed in 10CFR 50.92, the following discussions are provided to the'NRC Staff in support of "No Significant Hazards Considerations."

1. No significant increase in the probability or the consequences of an accident previously evaluated results from this change because:

There is no change in system design or operation. The license condition currently requires upgrade of NMS during the first refueling outage. This change will extend the modifications to RF2.

This license condition proposed change will allow operation with the currently installed system which has previously been accepted for interim. operation. This system is required to provide neutron flux indication and is. not postulated to initiate any accidents.

Therefore, -delay in upgrade to RG 1.97 requirements will not significantly increase the probability of an accident. The neutron monitoring system is used to verify reactor shutdown as part of the Emergency Operating Procedures (EOPs). The use of neutron monitoring in the E0Ps is conservative in that, if it is not available, actions are specified which will lead to safe shutdown without the system. The requirements of RG 1.97 concerning neutron monitoring are an enhancement to the existing system which would lead to the system being operable during accident scenarios for which it is not currently designed. However, delay in RG 1.97 modifications will not lead to an increase in the consequences of an accident as defined in the safety analysis due to the conservative E0P actions.

2. This change would not create the possibility of a new or different kind of accident from any accident previously evaluated because:

The current system has been evaluated and is currently a:cepted for interim operation. This change does not involve any changes to design or operation. In addition, the neutron monitcring system is not postulated as the initiator of any accidents. Therefore, no new or different accidents are created.

3. This change would not involve a significant reduction in the margin of safety because:

Design, function, and operation of the existing neutron monitoring system remain the same. There is no specified " margin of safety" associated with this system as used in RG 1.97 other than to assure reactor shutdown following a transient or accident. EOP actions are conservative with respect to the use of neutron monitoring for verification that the reactor is shutdown. When not available during an accident or transient scenario, actions are specified which will lead to reactor shutdown. Because these actions lead to a safe plant condition (reactor shutdown), the margin of safety is not reduced. In addition, this request does not result in a reduction to the margin of safety as defined in the bases of the RBS Technical Specifications.

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R,evised License Condition The requested revision is provided in the Enclosure.

Schedule For Attaining Compliance RBS is currently in compliance with the applicable section of the license condition. This proposed change is required prior to start-up following the first refueling outage.

Nottffcation of State Personnel l

A copy of the amendment application and this submitta'l has been provided to the state of Louisiana, Department of Environmental Quality - Nuclear Energy Division.

Environmental Impact Appraisal Revision of this Technical Specification does not result in an i environmental impact beyond that previously analyzed. Therefore, the l approval of this amendment does not result in a significant '

environmental impact nor does it change any previous environmental i impact statements for River Bend Station. l

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i i ATTACHMENT 5

. ENCLOSUP.E T0-NPF 47

'l EMERGENCY RESP 0kSL CAPABILITIES GSU shall complete the following requirements of HUREG-0737 Supplement il l on the schedule noted bclow:

1. Actions and schedules for correcting all human engineering dis-crepancies (NEDs) identified in the " Detailed Control Room Design Review Sumary Report dated October 31, 1984 and S'upplements dated '

May 14 June 12, 1985, and July 31, 1985, shall be implemented in accordance with the schedule comitted to by GSU in the sumary re-port and supplements and accepted by the NRC staff in Section 18.1 of SSER 3.

second

2. Prior to startup.following the #4 cst refueling outage, GSU shall implement modifications (installation or upgrade) for th= it= neutron

. flux 'monitoringli;ted taiaw consistent with the guidance of Regulatory Guide 1.97, I Revision 2 unless prior approval of an alternate design ;f these 44 ems is granted by the NRC staff. These ite ; es listed in 00'J's letter ;f J= 24,1^05 ere:,

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