RBG-44133, Provides Util Proposed Administrative Controls to Be Issued as Part of Plant Amend Request 96-23 Re Change to Tech Specs Concerning Reactivity Anomalies,Aprm Setpoints & RPS Instrumentation

From kanterella
Jump to navigation Jump to search
Provides Util Proposed Administrative Controls to Be Issued as Part of Plant Amend Request 96-23 Re Change to Tech Specs Concerning Reactivity Anomalies,Aprm Setpoints & RPS Instrumentation
ML20216E481
Person / Time
Site: River Bend Entergy icon.png
Issue date: 09/05/1997
From: King R
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216E483 List:
References
RBF1-97-0257, RBF1-97-257, RBG-44133, NUDOCS 9709100203
Download: ML20216E481 (7)
v • d • e


Text

.. . _ - _-- - - - - . . - - . -.-- -

entegy opercu:n.. ine.

, Q (Uwf bedid Stinhan

  • ses U L M #wn 61

- PO Box NO

-- .Entergy ==~

ra, smas m j nick J. xing I o,m, ib;i :stf t stdt 4y & $4tg.ilekny Atlif, September 5,1997 U. S. NRC Document Control Desk, OPI-17 l Washington, DC 20555

Subject:

Riverllend Station Unit 1 Docket No. 50-458 License No. NPF 47 Response to NRC Staffinquiries Regarding License Amendment Request (LAR) 96 23, Change to Technical Specifications Concerning APRhi Setpoints File Nos.: G9.5, G9.42 RBF197 0257 RilG 44133 Ladies and Gentlemen:

The purpose of this letter is to provide Entergy Operations' proposed administrative controls to be issued as part of River Bend Station License Amendment Request (LAR) 96-23," Change to Technical Specifications Concerning Reactivity Anomalies, APRhi Setpoints, and RPS Instrumentation," submitted on August 29,1996 (RBG 43161). In addition, the letter describes two additional administrative changes to the Technical Specifications (TS) and the Bases which are necessary to implement the LAR.

In discussions with the NRC staff during June 1997, the NRC staff raised questions regarding the administrative controls necessary to ensure continued compliance with the technicaljustification that Entergy provided in support of the amendment request.

l Entergy recognizes the concerns that have prompted the NRC to review their practices with respect to commitments recorded in documents such as staff Safety Evaluation Reports \

(SERs). Ilowever, we are concerned that the new processes discussed in SECY 97-036,' l "hiillstone Lessons Learned Report, Part 2: policy issues," to explicitly identify, track, enforce, and verify implementation of commitments associated with licensing actions have apparently been implemented without an opportunity for public discussion of the new process. We are specifically concerned about the potential for increased reliance on license

~

97o9100203 9709'5 o r,o" ^oock o'

=o .

@H0ggy

' ' Response to NRC Staffinquiries Regarding License Amendment Request (1,AR) 96 23, Change to Technical SpeelHc:tions Concerning APRM Setpoints September 5,1997 RilF197 0257 RIld44133 Page 2 0f 3 conditions when less burdensome alternatives- such as inclusion in the Updated Safety Analysis Report would appear to satisfy NRC objectives with respect to these commitments.

This new direction appears to contradict the regulatory direction taken with the promulgation of revised 10 CFR 50.36," Technical Speelfications." In the Final Policy Statement on Technical Specifications improvements for Nuclear Power Reactors, the NRC stated,in part:

" there has been a trend towards including in Technical Specifications not only those requirements derived from the analyses and evaluation included in the safety analysis l report but also essentially all other Commission requirements governing the operation of nuclear power reactors. It has diverted both staff and lleensee attention from the more important requirements in these documents to the extent that it has resulted in an adverse but unquantifiable impact on safety."

Entergy is concerned that this new position will again introduce unneeded requirements into the Technical SpeciHeations, thereby diverting resources from more important requirements.

l As such, Entergy proposes that the administrative controls requested by the NRC for this amendment be implemented by Updated Safety Analysis Report (USAR) changes in combination with existing requirements as described in the attachment to this letter. The proposed controls on the flow and power dependent limits will continue to assure adherence to the fuel thermal mechanical limits and the fuel integrity safety limits. The detailed basis supporting the adequacy of the proposed controls is included as Attachment l A; the related USAR changes are shown as Attachment it l Two additional administrative changes associated with the proposed I.AR have been l identified. With the elimination of T Factor Setdown requirements, statements referring to APRM gain and setpoints should be deleted from TS SR 3.3.1.1.2 and 5.6.5a as identified in the attachments. These changes are administrative given the prior deletion of TS 3.2A in its entirety. Neither of the deletions will alter the use and application of these l specifications. A proposed revision to the 13ASES is also included in support of these changes, The additional TS changes are shown in Attachment C; the proposed Bases changes are included as Attachment D.

l l

l l

  • Response to NRC StalTinquiries Regarding Licease Amendment Request (LAR) 96 23, Change to Technie:1 Specifications Concerning APRM Setpoints '

September 5,1997 RilF197 0257 Rild-44133 Page 3 of 3 The information provided herein does not impact the scope of the original submittal nor does it affect the No Significant llazards Consideration previously submitted with the original lleense amendment. If you have any additional questions or require additional information, please contact Mr. T. W. Oates at (504) 381 4866.

Sincerely,

& (W 0.T U RJK/rWG Attachments cc: Mr. David L. Wigginton U. S. Nuclear Regulatory Commission M/S OWFN 13113 Washington, DC 20555 .

NRC Resident inspector P. O.130x 1050 St. Francisville, LA 70775 U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011 Depar1 ment of Environmental Quality Radiation Protection Division P. O.130x 82135 Ilaton Rouge, LA 70884 2135 Attn: Administrator

~ . - - - - . . - . . _ . --_. .

Attachment A to HUG-44133 I

l Dewription of Administrative Controls Associated with T-Factor Elimination In discussions related to this amendment, the NRC staff suggested that three license conditions

[ tere under consideration to ensure that Entergy Operations fulfilled certain obligations arising Trom NRC approval of the pmposed license amendment and continued to comply with certain aspect = of the underlying technicaljustification for the change. River Bend Station continues to belies e the current controls in the License, Technical Specifications and the commitments in support of the Core Operating Limits Report will ensur af the licensing basis of the plant will be rr.aintained. The NRC proposed controls were addition I license conditions as described below: #

1. Prior to implememation, the licensee will validate the off rated power and flow-dependent z

MCPR and LilGR curves associated with the removal of the APRM setpoint T-factor. This 5 j validation and results will be included in the next update of the River Bend Station Updated -

Safety Analysis Report (USAR).  !

2. Prior to implementation, the licensee will verify the applicability of the plant specific, power-dependent MCPR and LHGR limits to include conservative ~ nargins to the limits calculated during the initial MEOD application. This verification and results will be included in the next update of the USAR.
3. Prior to implementation and for future reloads, the licensee will verify une plant-specific MCPR and LHGR limits for low pawer range between 40% and 25% rated thermal power using the GEXL-PLUS correlation and the GEMINI analysis methods. These limits will be ,

included in the Core Operating Limits Report. (COLR). l As an alternative to the suggested licenv conditions, Entergy believes that portions of the NRC proposed controls may bc implemented through changes to the River Bend USAR. The changes to the USAR, in conjunction with existing Technical Specification requirements, provide appropriate controls to ensure compliance with the NRC suggested license conditions as well as all relevant aspects of the plant licensing basis.

!' Sp,cifically, the current Technical Specification identifies LHGR, TS 3.2.3 and MCPR, TS 3.2.2, as items to be controlled by, and included in, the COLR. With the removal of the T-Factor setdown requirements of TS 3.2.4, the fuel protection for off-rated operations currently provided by the APRM setpoints adjustment will be assumed by specifications 3.2.3 and 3.2.2. With the LHGR and MCPR limits developed as described in GESTAR and depicted in the COLR, the appropriate fuel thermal - mechanical and the fuel integrity safety limits will be maintained.

These limits will need to be established for each reload cycle as required by TS 5.6.5 such that they continue to assure adherence to the fuel thermal - mechanical limits and the fuel integrity i

s_ .

Attachment A to RBG-44133 Page 2 of 2 safety limits. Therefore, with the raw power and Dow-dependent MCPR limits and LilGR

{

limits, operation willin design and regulatory limits is assured.

=

The RBS USAR will also be revised to include descriptions of the initial process of implementation and the cycle specific reviews. A new section,15.0.8, will be added to the USAR as proposed in Attachment C. This infonnation will include the calculation of cycle specific thermal limits and the verification of the plant specific limits for the low power range as described in proposed section 15.0.8.2 using methods described in GESTAR II. The necessary cycle specific results will be included in the supplemental reload licensing report (SRLR) developed, in accordance with GESTAR, in support of each COLR revision for each fuel cycle.

These power and Cow-dependent limits of the SRLR will be updated prior to implementation of the T-factor setdown elimination and as needed for future cycles.

s With these USAR changes concurrent with implementation of LAR 96-23, the NRC concerns regarding coatinued compliance are enveloped by TSs 3.2.2,3.2.3 and 5.6.5 (b.1) and the methods contained in GESTAR 11 as described in the information proposed for incorporation into the RBS USAR. The methods and limits for operation will be identified in tl. Technical Specifications and the USAR. This additional USAR information will be controlled in accordance with plant procedures and the requirements of 10 CFR 50.59.

The proposed USAR information discussing the initial implementation and cycle specific verification of the MCPR and LHGR limits is provided as Attachment B.

Attochment B to RilG-44133 Additional USAR Changes The following is the proposed USAR information discussing the initial implementation and cycle specific verification of the hiCPR and LilGR limits.

15.0.8.0 Eliminatiou of T-Factor Setdown 15.0.8.1 Initial Analyses The RBS Technical Specifications prior to Cycle 8 required that the APRhi flow-biased scram and control rod block trip setpoints be setdown (lowered) when the T-factor exceeded 1.0 for LIIGR protection. The T-Factor Setdown requirements were removed to reduce the need for manual setpoint adjustment and to allow more direct thermal limits administration. The setdown requirements were replaced by the flow- and power-dependent thermal limits which are documented on a cycle specific basis in the Core Operating Limits Report (COLR). A General Electric ant. lyses (NEDC-32489P) was performed to support this change which was implemented prior to Cycle 8 via Amendment _ to the RBS Technical Specifications.

Two areas which can be impacted by the climination of the setdown requirement are: a) fuel thermal-mechanical integrity, and b) loss-of-coolant accident (LOCA) analysis. The following criteria assure satisfaction of the above requirements and were applied to demonstrate the acceptability of elimination of the APRht trip setdown requirements:

(1) hiCPR safety limit shall not be violated as a result of any AOOs (2) All fuel thermal-mechanical design bases shall remain within the licensing limits described in the GE generic fuel licensing report GESTAR-II.

(3) Peak cladding temperature and maximum cladding oxidation fraction following a LOCA shall remain with the limits defined in 10 CFR 50.46.

The power- and flow-dependent hiCPR and LIIGR limits for T-factor setdown elimination were developed as part of the Maximum Extended Operating Domain (MEOD) performance l

improvement program for the BWR/6 class of plants (GESTAR Section S.5.2.7, S.5.2.6 and l 4.3.1.2.7). The MEOD program determined that the power-dependent severity trends must be examined in two power ranges. The first range is between rated power and the power level (P-BYPASS) where reactor scram on turbine stop valve closure or turbine control valve fast closure is bypassed. P-BYPASS for RBS is 40% of rated power. The second power range is between P-bypass and 25% of rated power. No thermal monitoring is required below 25% power because of the substantial margin that exists to h1CPR and LilGR limits below 23% thermal power.

Attachment B to RBG-44133 Page 2 of 2 For theinitial analyses (NEDC-32489P), plant specific power-dependent MCPR and LHGR limits were developed for use in the first power range. These power dependent limits must be updated or the current limits validated for future operating cycles to account for changes in fuel designs, analyses methodology and/or plant operating parameters.

For the initial analyses (NEDC-32489P), plant-specific evaluations were performed in accordance with GE- Nuclear Energy procedures to confirm the applicability of these limits to RBS. These limits are established on a cycle-independent basis but must be validated or updated for 25-40 % rated thermal power to account for changes in future fuel designs, analysis methodology and/or plant operating parameters.

The flow-dependent LHGR limits are also verified against the LOCA analysis to demonstrate that these flow-dependent LHGR limits also provide more than adequate fuel protection for postulated LOCA events.

Prior to the implementation of the T-Factor setdown climination at Cycle 8, the power and flow-dependent limits were verified and updated as documented in the SRLR which is generated in accordance with GESTAR. These flow and power-dependent limits assure that no safety limit will be exceeded.

15.0.8.2 Cycle Specific Analyses and Results The plant-specific MCPR and LHGR limits for low power range between 40% and 25% rated thennal power will be verified or updated each reload cycle using the GEXL-PLUS correlation and the GEMINI analysis or other applicable approved methods as described in NEDE-24011-P-A (GESTAR 11).

The verification of the power and flow-dependent limits including the MCPR and LHGR limits for the power range between 40% and 25% rated thermal power was performed for cycle 8 and the updated limits documented in the Cycle 8 SRLR (Reference x). These limits are included in the Core Operating Limits Report.

Subsequent reload analyses will include the validation of these powr and flow-dependent limits

'or development of r.ew limits, as appropriate, due to core design, fuel design loading changes and cycle specific SLMCPR. For future cycles, the power and flow dependent LHGR calculations will be performed m accordance with GE procedures using the methodology which supports the fuel thermal - mechanical protection featurmf the ARTS Analysis Option described in NEDE-240llP-A-ll-US (GESTAR 11 Sectiord U 6 of the US Supplement). The ARTS off-rated fuel thermal - mechanical protection methodGgy which applies to the BWR/3 through BWR/5 product lines is identical to the methodology used to calculate oft-rated fue; thermal - mechanical protection limits for a BWR/6. Therefore, this methodology can be specifically applied to power and fiow dependent LHGR limits which provide fuel thermal - mechanical protection for River Bend Station at off-rated conditions.

Retrieved from "https://kanterella.com/w/index.php?title=RBG-44133,_Provides_Util_Proposed_Administrative_Controls_to_Be_Issued_as_Part_of_Plant_Amend_Request_96-23_Re_Change_to_Tech_Specs_Concerning_Reactivity_Anomalies,Aprm_Setpoints_%26_RPS_Instrumentation&oldid=3268806"