RBG-46214, Application for Technical Specification Improvements to Revise Technical Specification 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves, Using the Consolidated Line Item Improvement Process

Application for Technical Specification Improvements to Revise Technical Specification 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves, Using the Consolidated Line Item Improvement Process

ML040420282
Person / Time
Site:	River Bend
Issue date:	02/03/2004
From:	King R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-46214
Download: ML040420282 (10)

Text

Aft Entergy Operations, Inc.

River Bend Station EntergEg}y 5485 U. S. Highway 61N St. Francisville LA 70775 Fax 225 635 5068 RBG-46214 February 3, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Application for Technical Specification Improvement to Revise Technical Specification 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves" Using the Consolidated Line Item Improvement Process (LAR 2004-03)

River Bend Station, Unit 1 Docket No. 50-458 License Amendment Request License No. NFP-47

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendment for River Bend Station, Unit 1.

The proposed changes would revise the required action within Technical Specification (TS) 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves" for the condition of having one or more SDV vent or drain lines with one valve inoperable. These changes are based on Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404 (Revision 0) that has been approved generically for the BWR/6 Standard Technical Specifications (STS), NUREG-1434, Revision 2. The availability of this TS improvement was announced in the Federal Register on April 15, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of Louisiana.

Attachment 1 provides a description of the proposed change and the requested confirmation of applicability. The existing TS pages annotating the proposed changes are provided in Attachment 2. Changes to the TS Bases associated with the proposed changes to TS 3.1.8 are provided in Attachment 3 for your information and will be implemented in accordance with TS 5.5.11, Technical Specification Bases Control Program. There are no new regulatory commitments associated with this proposed change.

Entergy requests approval of the proposed amendment by July 20, 2004. Once approved, the amendment shall be implemented within 60 days.

RBG-46214 Page 2 of 2 If you have any questions or require additional information, please contact Greg Norris at 225-336-6391.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 3, 2004.

Sincerely, R. J. King Director - Nuclear Safety Assurance RJK/MLC/GPN Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. Changes to Technical Specification Bases Pages- For Information Only cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U.S. Nuclear Regulatory Commission Attn: Mr. Michael K. Webb MS O-7D1 Washington, DC 20555-0001 Mr. Prosanta Chowdhury Program Manager - Surveillance Division Louisiana Department of Environmental Quality Office of Radiological Emergency Plan and Response P. 0. Box 82215 Baton Rouge, LA 70884-2215

Attachment I RBG- 46214 Analysis of Proposed Technical Specification Change to RBG-46214 Page 1 of 2

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-47 for River Bend Station, Unit 1 (RBS). The proposed changes would revise the required action within Technical Specification (TS) 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves" for the condition of having one or more SDV vent or drain lines with one valve inoperable.

These changes are based on Technical Specifications Task Force (TSTF) change traveler TSTF-404 (Revision 0) that has been approved generically for the BWR (Boiling Water Reactor)/6 Standard Technical Specifications (STS), NUREG-1434, Revision 2. The availability of this technical specification improvement was announced in the Federal Register on April 15, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Operations, Inc., (Entergy) has reviewed the safety evaluation published on April 15, 2003 (68 FRI 8294) as part of the CLIIP. This verification included a review of the NRC staffs evaluation as well as the supporting information provided to support TSTF-404. Entergy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to RBS and justify this amendment for the incorporation of the changes to the RBS Technical Specifications.

2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the Technical Specification changes described in TSTF-404 or the NRC staffs model safety evaluation published on April 15, 2003.

3..0 REGULATORY ANALYSIS 3.1 Applicable Regulatory Requirements/Criteria Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any General Design Criterion (GDC) differently than described in the Updated Final Safety Analysis Report (UFSAR) 3..2 No Significant Hazards Consideration Entergy has reviewed the proposed no significant hazards consideration determination published on April 15, 2003 as part of the CLIIP. Entergy has concluded that the proposed determination presented in the notice is applicable to RBS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

to RBG-46214 Page 2 of 2 3.3 Environmental Considerations Entergy has reviewed the environmental evaluation included in the model safety evaluation published on April 15, 2003 as part of the CLIIP. Entergy has concluded that the NRC staff's findings presented in that evaluation are applicable to RBS and the evaluation is hereby incorporated by reference for this application.

4.0 COMMITMENTS There are no new regulatory commitments associated with this proposed change.

Attachment 2 RBG- 46214 Proposed Technical Specification Changes (mark-up) to RBG-46214 Page 1 of 1 SDV Vent and Drain Valves 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves LCO 3.1.8 Each SDV vent and drain valve shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS N ,,,

Separate Condition entry is allowed for each SDV vent and drain line.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SDV vent or A.1 o 7 days drain lines with one valve R Inoperable. t re +he a (he.

B. One or more SDV vent or a. I~

drain lines with both valves a .Altedln may

~~~~~~~~~~ioleatled under

\ ~~~~~~~~~~~~~administrative control to

~~~~~~~allow draining and(

Isolate the associated 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> line.

C. Required Action and C.1 Be In MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

RIVER BEND 3.1-24 Amendment No. 81

Attachment 3 RBG- 46214 Changes to Technical Specification Bases Pages For Information Only

- Attachment 3 to RBG-46214 Page 1 of 2 SDV Vent and Drain Valves B 3.1.8 BASES APPLICABLE allow continuous drainage of the SDV during normal plant operation to SAFETY ANALYSES ensure the SDV has sufficient capacity to contain the reactor coolant (continued) discharge during a full core scram. To automatically ensure this capacity, a reactor scram (LCO 3.3.1.1 'Reactor Protection System (RPS)

Instrumentation') Is nitiated if the SDV water level exceeds a specified setpoint. The setpoint Is chosen such that all control rods are inserted before the SDV has nsufficient volume to accept a full scram.

SDV vent and drain valves satisfy Criterion 3 of the NRC Policy Statement.

LCO The OPERABILITY of all SDV vent and drain valves ensures that during a scram, the SDV vent and drain valves will close to contain reactor water discharged to the SDV piping. Since the vent and drain ines are provided with two valves In series, the single failure of one valve n the open position will not impair the Isolation function of the system. Additionally, the valves are required to be open to ensure that a path Is available for the SDV piping to drain freely at other times.

APPLICABILITY In MODES I and 2, scram may be required, and therefore, the SDV vent and drain valves must be OPERABLE. In MODES 3 and 4, control rods are not able to be withdrawn since the reactor mode switch is in Shutdown and a control rod block Is applied. This provides adequate controls to ensure that only a single control rod can be withdrawn. Also, during MODE 5, only a single control rod can be withdrawn from a core cell containing fuel assemblies. Therefore, the SDV vent and drain valves are not required to be OPERABLE In these MODES since the reactor is subcritical and only one rod may be withdrawn and subject to scram.

ACTIONS The ACTIONS table is modified b otin~dicating that a separate Condition entry Is allowed for eachS'V vent and drain line. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable SDV line.

Complying with the Required Actions may allow for continued operation, l-v'zse rk 1 and subsequent Inoperable SDV lines are governed by subsequent r*A-pow L opndition entry and application of assodated Required Actions.

(continued)

RIVER BEND B 3.1-46 Revision No. 0

I Attachment 3 to RBG-4621 4 Page 2 of 2 SDV Vent and Drain Valves B 3.1.8 ACTIONS A.1 \; t o (continued) '4or tr\%

\^ Wn one SDV vent or drain valve is ino erable more l ines, the va'emusRZ resio OPERABstatus ithii-?'da3.The - - 7l \

Completion me Isreasonable, given the level ofIrdudancy Inthe lines and the law probability of a scram occurring during the time the valve(s)

A \;A * > are Inorabie. The SDV Is still isolable since the redundant valve In the Ckns Vvno zInc Is afectemeis

/ OPERABLE. Since the SDV Isstill Isolable, the affected CAt 'Is 0 SDV line maybe opened. This allows accumulated water In the line to be drained to preclude a reactor scram on SDV high level. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

MoveS aryevibl% )

Na Ii Qi isla .uring these periods, the line may be unisolated under administrative control. This allows any accumulated water In the line to be drained, to predude a reactor scram on SDV high level. This is acceptable. since the administrative controls ensure the valve can be closed quickly, by a dedicated operator, if a scram occurs with the valve The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time to Isolate the line Is based on the low probability of a scram occurring while the line is not Isolated and unlikelihood of significant CRD seal leakage.

C.1 If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE In which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed Completion (continued) 2--W S V FIT

-The CT IONIS 4-aLL isf;t~A4 6i o se,,,jj N .S4Trsui 5 44Al M'o Cri ine rsy \Ze uri'skeA Arger RIVER BEND B3.1-47 Revision No. 0