RBG-46233, Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process, LAR 2004-04

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process, LAR 2004-04

ML040720326
Person / Time
Site:	River Bend
Issue date:	03/04/2004
From:	Hinnenkamp P Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 2004-04, RBG-46233
Download: ML040720326 (12)

Text

Ad Entergy Operations, Inc.

River Bend Station 5485 U. S. Highway 61 N

> teoVSt.

>E Francisville. LA 70775 Fax 225 635 5068 RBG-46233 March 4, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process, LAR 2004-04 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 to the Technical Specifications (TS) for River Bend Station, Unit 1 (RBS).

The proposed amendment will delete the TS requirements related to hydrogen recombiners and hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Implementation of TSTF-447 also involves various changes to the TS Bases. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.11, 'Technical Specifications (TS) Bases Control Program."

The proposed change includes a new commitment as summarized in Attachment 3.

Entergy requests approval of the proposed amendment by July 2, 2004. Once approved, the amendment shall be implemented within 120 days.

pOCc

RBG-46233 Page 2 of 2 If you have any questions or require additional information, please contact Ron Byrd at 601-368-5792.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 4, 2004.

Sincerely, Paul D. Hinnenkamp Vice President, Operations River Bend Station PDH/RWB Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. List of Regulatory Commitments 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 0-7D1 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-46233 Analysis of Proposed Technical Specification Change

Attachment I to RBG-46233 Page 1 of 3

1.0 INTRODUCTION

This letter is a request to amend Operating License NPF-47 for River Bend Station, Unit 1 (RBS). The proposed License amendment deletes Technical Specification (TS) 3.6.3.1, "Primary Containment Hydrogen Recombiners," and references to the hydrogen monitors in TS 3.3.3.1, uPost Accident Monitoring (PAM) Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, 'Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

Table 3.3.3.1-1 Item 10, Drywell H2 Analyzer Deleted Item 11, Containment H2 Analyzer Deleted TS 3.6.3.1 Primary Containment Hydrogen Deleted Recombiners As described in NRC-approved Revision I of TSTF-447, the changes to TS requirements results in changes to various TS Bases sections. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.11, "Technical Specifications (TS) Bases Control Program." At this time, Entergy is not changing the Bases discussions for TS 3.6.3.2, Primary Containment and Drywell Hydrogen Igniters, regarding the use of a recombiner and a hydrogen mixing subsystem as an alternate method of performing the hydrogen control function. This information was to be deleted by TSTF-447. Maintaining an alternate method of performing the hydrogen control function is required to allow continued operation for 7 days if both hydrogen igniter divisions are inoperable (see Required Actions and Completion Times associated with Condition B of TS 3.6.3.2).

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

to RBG-46233 Page 2 of 3

5.0 TECHNICAL ANALYSIS

Entergy has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE, as well as the supporting information provided to support TSTF-447. Entergy has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to RBS and justify this amendment for the incorporation of the changes to the RBS TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, Entergy is making the following verifications and regulatory commitments:

1. Entergy has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at RBS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual (TRM). This regulatory commitment will be implemented within 120 days of amendment issuance.

2. RBS does not have an inerted containment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Entergy has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) 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).

8.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. Entergy has concluded that the staff's findings presented in that evaluation are applicable to RBS and the evaluation is hereby incorporated by reference for this application.

to RBG-46233 Page 3 of 3 9.0 PRECEDENT This application is being made in accordance with the CLIIP. Entergy is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staff's model SE published on September 25, 2003 (68 FR 55416).

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003, (68 FR 55416).

Attachment 2 RBG46233 Proposed Technical Specification Changes (mark-up) to RBG-46233 Page 1 of 3 PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM REQUIRED REQUIRED FUNCTION . CHANNELS ACTION D.1

1. Reactor Steam Dome Pressure 2 E

2. ReactorVesselWaterLevel- Wde Range 2 E

3. ReactorVessel WaterLevel-FuelZone 2 E

4. Suppression Pool Water Level 2 E

5. Suppression PoolSectorWaterTemperature 2 (a) E

6. Drywell Pressure 2 E

7. Primary Containment Pressure 2 E

8. Drywell Area Radiation 2 F

9. Primary ContainmentArea Radiation 2 F 10 D 1Amlyr ilfef bejeie .

12. Penetration Flow Path, Automatic PCIV 2 per penetration E Position flow path (b)(c)

(a) Monitoring each of two sectors.

(b) Not required for isolation valves whose associated penetration flow path is isolated.

(c) Only one position indication channel is required for penetration flow paths wAth only one control room indication channel.

RI'VER SEND 3.3-22 Amendment No. 9t 95 to RBG-46233 Page 2 of 3 Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 fl::;rnbin:ee

_mrF,'Gotainrrwrt tEH/dcge ICO 3.6.3.1 Two primary cont ainment hydrogen recombiners shall be OF PERABLE.

AP ICABILITY: MODES I and 2.

ACTIONS i CTION REQUIRED ACTIO CO ETI-ON TIME

-- I !f I

-f

. A. One primary co inment A.1 b-NOTEo hydrogen recombi r LCO 3.0.4 is not inoperable. applicable.

Restore priHry 30 days containm hydrogen recomb' or to OPE LE status.

B. Two primary containment 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> hydrogen recombiners inoperable.

, function is AND B.2 Restore one pdimaryN containment hydrogen 7 days recorrbiner to OPERABLE status.

C, Re ed Action and C.1 Be In MODE 3.

sociated Completion lime not met.

O --..I

-N RIVER BEND 3.6-39 Amendment No, 81 to RBG-46233 Page 3 of 3 Primary Containment Hydrogen Recombiners 3.6 SURVEI REQUIREMENTS SURVEILLANCE ,<REQUENCY SR 3.6.3.1.1 Perform a functional test for eac 18 months containment hy en recombiner.

SR 3.6.3.1.2 Visually examine e primary inment 18 months hydrogen rec stncr entround t her 1s no eiefabnormal conditions SR 3.6.3.1.3/Perform a resistance to ground test for each heater o r

/ ~ pae.\

RIVER BEND 3.6-40 Amendment No. 81

Attachment 3 RBG-46233 List of Regulatory Commitments

I I -

Attachment 3 to RBG-46233 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (C eck one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Entergy has verified that a hydrogen monitoring X Within 120 system capable of diagnosing beyond design-basis days of accidents is installed at RBS and is making a amendment regulatory commitment to maintain that capability. issuance.

The hydrogen monitors will be included in the Technical Requirements Manual (TRM).

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