RBG-45094, Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation

Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation

ML20211G598
Person / Time
Site:	River Bend
Issue date:	08/25/1999
From:	King R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-458-98-16, RBF1-99-0224, RBG-45094, NUDOCS 9908310297
Download: ML20211G598 (6)

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Entergy Oper;ti:ns, Inc.

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Rwer Bend Station 5485 U S. Highway 61 p O. Box 220 i225 36 2'2 Fax 225 035 5068 Rick J. King August 25,1999 RZ Sateh Asm e U.S. Nuclear Regulatory Commission Document Control Desk, OP3-17 Washington, D.C. 20555

Subject:

Response to Notice of Violation in IR 50-458/98-16 River Bend Station - Unit i License No. NPF-47 Docket No. 50-458 File Nos.: G9.5, G15.4.1 RBG-45094 RBF1-99-0224 Ladies and Gentlemen:

The NRC's staff letter of June 30,1999 addressing Notice of Violation 50-458/9816-EA-425 requested that Entergy Operations, Inc. (EOI) submit to NRC the corrective actions taken to correct the specific violation and the actions to prevent recurrence within thirty days of the letter's receipt. In discussions 1 between River Bend Station and Mr. Dale Powers, EOl was granted an extended '

due date of August 25,1999.

The subject of Notice of Violation 50458/9816-EA-425 concerned License Change Notice (LCN) 15.6-006 that revised the calculation of the off-site dose analysis for a loss of coolant accident (LOCA). Since both the General Design Criteria (GDC) and 10CFR100 were used as the basis for approval of the RBS Safety Evaluation Report and Technical Specifications (TS) Amendment 98, EOl contended that the changes made by LCN 15.06-006 were within the regulatory limits previously approved by the NRC.

Entergy considers this violation to be a generic issue related to the industry and NRC interpretations of the existing 10CFR50.59 rule. EOl is aware that this 1 generic issue and others regarding the 10CFR50.59 rule will be resolved through i

new rulemaking (SECY-99-130). 1

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i August 25,1999 Reply to Notice of Violation 50-458/98016-EA425 RBG-45094 -

RBF1-99-0224 Page 2 of 2 EOl has reviewed the NRC's decision as it applies to RBS and does not agree with the conclusion. However, pursuant to the provisions of 10 CFR 2.201, EOl is providing a reply to the Notice of Violation as Attachment 1 to this letter.

Attachment 2 contains a list of commitments associated with this response. We do not wish to pursue this issue through the backfit process and will await the final rule implementation.

Should you have any questions regarding the attached information, please contact Mr. David Lorfing of my staff at (225) 381-4157.

Sincerely, cc < ,

RJK/rlb Attachment CC:

U. S Nuclear Regulatory NRR Project Manager, Robert Fretz Commission U.S. Nuclear Regulatory Commission Region IV M/S OWFN 04DO3 611 Ryan Plaza Drive, Suite 400 Washington, D.C. 20555 Arlington,TX 76011 I NRC Sr. Resident inspector Director Office of Enforcement P.O. Box 1050 U.S. Nuclear Regulatory Commission l

St. Francisville, LA 70775 Washington, D.C. 20555-0001 l l

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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-458/98016-EA425 Page 1 of 3 l Violation: l During a NRC inspection conducted between July 20 and August 7,1998, a l violation of NRC requirements was identified:

10 CFR 50.59(a)(1) states, in part, that a holder of a license authorizing l operation of a production or utilizstion facility may make changes in the facility as described in the safety analysis report (SAR) without prior l Commission approval unless the proposed change involves an unreviewed l safety question.

10 CFR 50.59(a)(2) states, in part, that a change shall be deemed to involve an unreviewed safety question if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously analyzed in the safety analysis report may be increased.

Contrary to the above, on July 24,1998, the licensee made a change to the facility as described in the safety analysis report, which created an unreviewed safety question, without obtaining prior Commission approval. '

Based on a revised calculation, the radiological doses for a loss of coolant accident (LOCA) as reported in Table 15.6-7 of the Updated Safety Analysis Report (USAR) were increased. Specifically, the Exclusion Area Thyroid dose increased from 32.8 to 37.8 rem and the Low Population Zone Thyroid dose increased from 50.3 to 115.1 rem. Because this change involved an increase in the consequences of an accident previously analyzed in the safety analysis report, it constituted an unreviewed safety question for which prior Commission approval was required.

Background:

In the Entergy Operations, Inc., (EOI) response, dated February 11,1999 to Notice of Violation 50-458/-16-EA-425, EOl contended that changes made by Licensing Change Notice (LCN) 15.6-006 were in fact within regulatory limits when previously reviewed by the NRC and did not constitute an Unreviewed l Safety Question (USO). The basis for this position was that the change in loss of coolant accident offsite doses were bounded by the acceptance criteria of 10CFR100 and GDC 19 which was used as the basis for the RBS Safety Evaluation Report and the review of Amendment 98.

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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-458/98016-EA425 Page 2 of 3 1

1 in the SER supporting RBS Technical Specification (TS) Amendment #98, the NRC measured acceptability of the doses against the limits of 10CFR100 and i j GDC 19.

When RBS evaluated the LCN using existing industry guidelines, the doses were within the acceptance limits used by the NRC in the RBS evaluation of LOCA dose consequences and regulatory limits (established in 10CFR100 and GDC- )

19). This approa; was consistent with industry practices and consistent with I the guidance of NEl-96-07, which has been adopted by the industry as a l guidance document for 10CFR50.59 reviews. Our conclusion was that no unreviewed safety question would be created by the change to the USAR.

The primary contributor to the increased dose within the calculation was an  !

additional conservative term added to bound any beyond licensing and beyond design basis Engineered Safety Feature (ESF) leakage to areas outside of l secondary containment. This term was added as a result of re-review of NRC '

information Notice (lN) 91-56. The review was conducted to establish Inservice  ;

Testing (IST) leakage limits for High Pressure Core Spray (HPCS) and Reactor l Core isolation Cooling (RCIC) lines to the Condensate Storage Tank (CST) and for the addition of the Suppression Pool Cleanup and Cooling System. ii nas concluded that no additional liquid leakage terms needed to be added to the  !

dose analyses. l However, an additional conservative term was added per Section lli of the NRC guidance in Standard Review Plan (SRP) Section 15.6.5, Appendix B that assumes a 50 GPM leak exists starting 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the accident and lasting for 30 minutes. Since any beyond licensing and beyond design basis liquid leakage outside secondary containment would not be subject to ESF filtration, it l was reasonable and consistent with NRC guidance in the SRP and the l NEl-96-07 guidance concerning 50.59 evaluations to use this leakage term l as a conservatism. In Task Interface Agreement (TIA) 94-22, the NRC stated I that to require licensees to assume radioactive water leakage to the atmosphere would be a compliance backfit.

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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-458/98016-EA425 Page 3 of 3 The only purpose for including this term was to preserve margin below the 10CFR100 limits; as such, this term is pertinent and consideration of it demonstrates a commitment to conservative treatment of offsite doses under the industry guidance of NEl-96-07, Revision 0 and NSAC-125. Had the calculation been performed without this additional conservatism added, the change would have met the new rule's criteria of a change within ten percent for a minimal increase in consequences, i.e., a change of less than ten percent of the remaining margin to 10CFR100 or SRP dose acceptance criteria.

Corrective actions:

. River Bend Station will submit for NRC approval the changes associated with LCN 15.06-006 and its accompanying ovaluation.

. Until the new rule has been implemented, River Bend Station will submit for NRC approval all future 10CFR50.59 evaluations that result in an increase in dose consequences above the limits planned for implementation in the new rule.

Date when full compliance will be achieved:

Compliance will be achieved upon the completion of NRC approval of the River Bend Station LCN 15.06-006 submittal. This submittal is scheduled for October 31,1999.

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ATTACHMENT 2 COMMITMENT IDENTIFICATION FORM 50-458/98016-EA425

! Page 1 of 1 I Violation 50/458/98016-EA425 COMMITMENT ONE- CONTINUING TIME COMPLIANCE

- ACTION  ;

River Bend Station will submit for NRC approval the i changes associated with RBS's LCN 15.06-006 and its X i

accompanying evaluation.

Until the new rule has been implemented, River Bend X l Station will submit for NRC approval all future 10CFR50.59 l evaluations that result in an increase in dose l consequences above the limits planned for implementation

! in the new rule.

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