RBG-46690, License Amendment Request, Application for Technical Specification Changes Using the Consolidated Line Item Improvement Process (CLIIP)

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License Amendment Request, Application for Technical Specification Changes Using the Consolidated Line Item Improvement Process (CLIIP)
ML082120078
Person / Time
Site: River Bend Entergy icon.png
Issue date: 07/28/2008
From: Mike Perito
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-46690
Download: ML082120078 (17)
v • d • e


Text

Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N Entergy St. Francisville, LA 70775 Tel 225-381-4795 Michael Perito Vice President, Operation RBG-46690 July 28, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request Application for TechnicalISpecification Changes Using the Consolidated Line Item Improvement Process (CLIIP)

River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47

REFERENCE:

Federal Register Notice 72 FR 63935, published November 13, 2007

Dear Sir or Madam:

In,accordance with the provisions of 10 CFR 50.90 Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the technical specifications (TS) for River Bend Station, Unit 1 (RBS). The proposed amendment would: (1) revise the TS surveillance requirement (SR) frequency in TS 3.1.3, "Control Rod OPERABILITY", (2) clarify the requirement to fully insert all insertable control rods for the limiting condition for operation (LCO) in TS 3.3.1.2, required Action E.2, "Source Range Monitoring Instrumentation," and (3) revise Example 1.4-3 in Section 1.4 "Frequency" to clarify the applicability of the 1.25 surveillance test interval extension. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the associated TS Bases changes. The proposed change includes one new commitment as summarized in .

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10CFR50.92(c) and it has been determined that this change involves no significant hazards. consideration. The bases for these determinations are included in the attached submittal.

Entergy requests approval of the proposed amendment as soon as practical. Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

/166/

RBG-46690 Page 2 of 2 If you have any questions or require additional information, please contact David Lorfing at (225) 381-4157.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 28, 2008.

Sincerely, Vice President, Operations River Bend Station - Unit 1 JCR/DNL/bmb 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
4. List of Regulatory Commitments cc: Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U.S. Nuclear Regulatory Commission Attn: Mr. Jack Donohew Jr. OWFN MS 8 G14 Washington, DC 20555-0001 Mr. Jeffrey P. Meyers Louisiana Department of Environmental Quality Office of Environmental Compliance Attn:OEC - ERSD P. 0. Box 4312 Baton Rouge, LA 70821-4312

Attachment I RBG-46690 Analysis of Proposed Technical Specification Change

Attachment 1 to RBG-46690

'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 amendment would:

(1) Delete SR 3.1.3.2 and revise SR 3.1.3.3, notch testing of withdrawn control rods, from "Insert each partially withdrawn control rod at least one notch" to "Insert each withdrawn control rod at least one notch." This change results in "A.2" of TS 3.1.3 being revised from "Perform SR 3.1.3.2 and SR 3.1.3.3 for each withdrawn OPERABLE control rod" to "Perform SR 3.1.3.3 for each withdrawn OPERABLE control rod." The note in SR 3.1.3.3 is also revised to limit the time period until the SR is to be performed from "38 days 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after the control rod is withdrawn" to "31 days after the control rod is withdrawn,"

(2) Add the word "fully" to LCO 3.3.1.2 Required Action E.2 to clarify the requirement to fully insert all insertable control rods in core cells containing one or more fuel assemblies when the associated Source Range Monitor (SRM) instrument is inoperable, and (3) Revise Example 1.4-3 in Section 1.4 "Frequency" to clarify that the 1.25 surveillance test interval extension in SR 3.0.2 is applicable to time periods discussed in NOTES in the "SURVEILLANCE" column in addition to the time periods in the "FREQUENCY" column.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) change traveler TSTF-475, Revision

1. The Federal Register notice published on November 13, 2007, announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT

2. 1 Applicability of Published Safety Evaluation Entergy has reviewed the safety evaluation dated November 13, 2007, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-475, Revision 1.

Entergy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are'applicable to River Bend Station, Unit 1 and justify this amendment for the incorporation of the changes to the River Bend Station, Unit 1 TS.

to RBG-46690 Page 2 of 2 2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the applicable TS changes described in the modified TSTF-475, Revision 1 and the NRC staff's model safety evaluation dated November 13, 2007.

Example 1.4-3 is revised by the TSTF to clarify the application of the surveillance interval extension allowance.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards ConsiderationDetermination Entergy has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. Entergy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to River Bend Station, Unit 1 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on November 13, 2007, for this TS improvement, Entergy verifies the applicability of TSTF-475 to River Bend Station, Unit 1, and commits to establishing TS Bases consistent with TSTF-475, Revision 1 as indicated in Attachment 4.

These changes are based on TSTF change traveler TSTF-475 Revision 1 that proposes revisions to the Standard Technical Specifications (STS) by: (1) Deleting SR 3.1.3.2 and revising SR 3.1.3.3, notch testing of withdrawn control rods, from "Insert each partially withdrawn control rod at least one notch" to "Insert each withdrawn control rod at least one notch." This change also revises "A.2" of TS 3.1.3 from "Perform SR 3.1.3.2 and SR 3.1.3.3 for each withdrawn OPERABLE control rod" to "Perform SR 3.1.3.3 for each withdrawn OPERABLE control rod." The note in SR 3.1.3.3 is also revised to limit the time period until the SR is to be performed from "38 days 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after the control rod is withdrawn" to" 31 days after the control rod is withdrawn," (2) Adding the word "fully" to LCO 3.3.1.2 Required Action E.2 to clarify the requirement to fully insert all insertable control rods in core cells containing one or more fuel assemblies when the associated Source Range Monitor (SRM) instrument is inoperable, and (3) Revising Example 1.4-3 in Section 1.4 "Frequency" to clarify that the 1.25 surveillance test interval extension in SR 3.0.2 is applicable to time periods discussed in NOTES in the "SURVEILLANCE" column in addition to the time periods in the "FREQUENCY" column.

4.0 Environmental Evaluation Entergy has reviewed the environmental evaluation included in the model safety evaluation dated November 13, 2007, as part of the CLIIP. Entergy has concluded that the staff's findings presented in that evaluation are applicable to River Bend Station, Unit 1 and the evaluation is hereby incorporated by reference for this application.

Attachment 2 RBG-46690 Proposed Technical Specification Changes (mark-up) to RBG-46690 Page 1 of 5 Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4ý2 (continued)

"Thereafter" indicates future perform-ances must be established per SR 3.0.2, but only after a specified condition is first met (ie-, the "or*ce" performance in Otis exampte), If reactor power decreases to

< 218%,RP,the measurement of both intervals stops. New intervals staid upon reactor power reaching 23.8% RTP, EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY,

NOTE ..........----

I .........

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

> 2318% RTR Perform channel adjustment. 7 days The interval continues whether or not the unit operation is < 23.8% RTP between performances.

As the Note modifies the required perfocmance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 23.8% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches - 23.8% RTP to perform the Surveillance. The Surveillance is still considered to be wi hin the "specified Frequency."

V'herefore, if the Surveillance wete rot performed within the 7 day inierval

{plus the extension allowed by SR 3.0,2), but operation was

< 2138% RTP., it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met. provided operaiion does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power 23.8% RTP, V

R-"',

'R K N'D i,0ý27 BED 1.-27Amendirneo R~.iR No, 84 , 114 to RBG-46690 Page 2 of 5 F-requ ency 1.4 1,4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)

Once the unit reaches 23.8% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval there would then be a failure to perform a Surveillance within the spified Frequency, and the provisions of SR 3.0.3 would apply. ..

EXAMPLE 1,44 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

.................-...... NOTE ----

Only required to be met in MODE 1.

Verify leakage rates are within limits. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4-4 specifies that the reqUirements of this Surveillance do not have to be met until the unit is in MODE 1. The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1, However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance. Therefore, if the Surveillance were not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (plus the extension allowed by SR 3.0.2) interval, but the unit was not in MODE 1. there w.ould be no failure of the SR nor failure to meet the LCO. Therefore. no violation of SR 3.0,4 occurs when changing MODES, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE 1 (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency were nol met), SR 3.0.4 would require satisfying the SR.

,RIVER SEND, 1.0o-28 Amendment No, a4, 114 to RBG-46690 Page 3 of 5 Control Rod OPERABILITY 31.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A- (continued) A.2 Perform% R3-*.arn 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from SR 3,13.3 for each discovery of withdrawn OPERABLE Condition A control rod. concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the Rod Pattern Control System (RPCS)

AND A.2 Perform SR 3.1.1.1. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Two or more withdrawn B. 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 /> control rods stuck.

C. One or more control rods C-1 ..------NOTE-...

inoperable for reasons Inoperable control rods other than Con dition A may be bypassed in or B. RACS in accordance with SR 13.2.1.9. if required, to allow insertion of inoperable control rod and continued operation, Fully insert inoperable 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> control rod, ANDD

.. 1(CO ti l ued)

. I

,RIVER BEND 3. '.- 7 Amendment No, 81 to RBG-46690 Page 4 of 5 Control Rod OPERABILITY

.31.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.1.3.2 ................ .- Ao ----- -

Not required to be pe-formed until 8 days

- y r 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after thppntrol rod is fully withd an and THERMAL/POWER is greater tha r1e LPSP if ,, of the RP .

I tec ul witfbdraw ontrol rod at least oner 7 days SR3.1.3.3 ..... ~~~~~............

. ... . N TE. . ...- ,-% .. ... .

SR 3.1.3.3 ----------------- NOTE - ----- ------

Not required to be performed until Wdays

,48-hett8rafter the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RPCS.

Insert.eachjadia1jvithdrawn control rod at least one 31 days notch.

SR 31.3A4 Verify each control rod scram time from fully in accordance with withdrawn to notch position 13 is a 7 seconds. SR 3.1,4.1, SR 3.1.4.2, SR 3.1.4-3, and SR 3,1.4.4 (continued)

RI',,'ER BEND Amendment No. 81 to RBG'-46690 Page 5 of 5 SR10 InstrUrnent'afion 3,3.1-2 ACTIONS CONDITION REQUIRED ACIrON COMPLETION TIME D. '(continued) D-2 Place reactor mode I hour Switch in the shutdown position.

E- One or more equired E. 1 Suspend CORE Immediately SRMs inoperable in ALTERATIONS except for MODE 5. control rod insertion.

-ANDQ E-2 Iniiate action tinsert all Immediately insertable control rods in core cells containing one or more fuel assemblies, RIVER BEND 113-11 ~r~D RIVER .3-11Amendmenet No. q-1

Attachment 3 RBG-46690 Changes to Technical Specification Bases Pages For Information Only to RBG-46690 Page 1 of 3 Control Rod OPERABILITY B 31,3 BASES ACTIONS A.1 A.2. and A.3 {continued) control rod can be isolated from scram by isolating the hydraulic control unit from scram and normal drive pressure, yet still maintain cooling waler to the CRD.

Monitoring of the insertion capability f t ,wtthdran control (od rr-q*.,

also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, * -C2-,j$R 3.1.3.3 perfA q periodic tests of the control rod insebif dithdrawn cont-re rods, Testing each withdrawn control rod ensures that a generic problem does not exist. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provides a reasonable time to test the control rods, considering the potential for a need to reduce power to perform the tests. Required Action A.2 has a modified time zero Completion Time. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time for this Required Action starts when the withdrawn control rod is discovered to be stuck and THERMAL POWER is greater than the actual low power setpoint (LPSP) of the rod pattern controller {RPC), since the notch insertions may not be compatible with the requirements of rod pattern control (LCO 3.1.6) and the RPC (LCO 3.3.2.1, "Control Rod Block Instrumentation').

To allow continued operation with a withdrawn control rod stuck, an evaluation of adequate SDM is also required within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Should. a DBA or transient require a shutdown, to preserve the single failure criterion an additional control rod would have to be assumed to have failed to insert when required. Therefore, the original SDM demonstration may not be valid. The SDM must therefore be evaluated (by measurement or analysis) with the stuck control rod at its stuck position and the highest worth OPERABLE control rod assurmed to be fully withdrawn.

The allowed Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to verify SDM is adequate, considering that with a single control rod stuck in a withdrawn position, the remaining OPERABLE control rods are capable of providing the required scram and shutdown reactivity. Failure to reach MODE 4 is only likely if an additional control rod adjacent to the stuck control rod also fails to insert during a required scram. Even with the postulated additional single failure of an adjacent control rod to insert, sufficient reactivity control remains to reach and maintain MODE 3 conditi.ons (Ref. 7).

_(continued)

RIVER BEND B 3.1-15 Revision No, 0 to RBG-46690 Page 2 of 3 Coin'roI Rod ()Pr.R!E51LlTY B3ASES fcontinLu5d)

SLJFRVIELLANCE aR 31 11I REQVIRF-r/hENTS

'1'?ipo.4o-iicn of. ac& oontrnI rod must be, deerrmined, to rtr adequate iniormaýn o-,n cootilrol positivn is avaiiable to tbe oper~z'f-r IC.

c6ternn n 'rrc1rd tra OPERABILITYr and contrt.4irg tuodphe.

Cow~rl L~oposition mnay be delarmi~rwe by th us,:of OPE RA~L F;NA slon ind'icators, by moving control r,,sd to a positon 'i~vh an OPEPAS3LE in colcaor, or by the uSe, ofýfthir ppropsiagtemetho~ds. !Ný24 houjr Frpnuencv of this SR is based on ope Al~ti ro xperienice relate, to ffb ~ epectei noon. at rod posilion and ,he avaii~abiliK of Control. rod ihn~

~ __ fosilion iri icariomt in he nolmlO aomý ConrolrI rod insertion capabititysi5"1 mtnl)Pat*id ,b' insertiir each pariially or ful-. ilhtrolfd ai least one notoiiharkd obsorving ffiat tbe wrih cunrurodi naes The~t-Ru rod may then be returned to qtariqira-I

>. poi .~nThis onsures the cxranrol rod is ft-t stuck,and is free tosrfn

- 'ýjaji sinl Tr-mdfe ytp~niyn t e t~iiureiInce ~not required to be~ perforrmed when TH1ERMAL POWE R is iCss ;han or equal to thoit~lual LPSP of the RPC since th notcu sertons mayorot bo ccrnptible with ýhe roqulrrernnts oftOlea 8PVVS (LCC 311,6) and the RPC (LWC3," VT~ o~as L--a timo aItoince..srir.h that Mie Surveillarnc-pafeii2-f

ýi7 requr ii

f be perNorrnrid urtil Ifir next scheduled controi rod te~sting for control rd~

(~j~sam ~ las- tie.tilly witdrai~ln of partially willithlAwn). 4i~e j Nallem pr-,,,iJiýthis alkwrmaazor pe-re-iiot unnocessary perturbdations in reactoraý,-+r~ation io performn this on F cc'ntmtf rudwhicse suivýefllance otas fu~ywthdr-aven or p~a Mially .vithdraw nI has *haqiged. -fi-H il.e,

.iyvrcJ&Partialli? withldawn conitral rods are tested at a 31 day Rrequency, bas~td on tho pocrltantpot iei reductihn rerguied to allow the mnro~l rod nmovaiemen ý1iyr Q n G4ngSfpe

(+S---4 3 F.urbiiren~oi o, the 31I da y Fre~quency take irto acou nt 1-'radrrri exri tenL tre-ae te- th.ngesin--1-R prfori.nn . Atsrvy

~Nme., ii -, c.uniol tod in Imitnovable a

  • tr,,,'ER BE*'*.) F13,1-lýt to RBG-46690 Page 3 of 3 SIRM Instrumentation B 3S.1.2 BASES ACTIONS D.1 and 0.2 (continued)

Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is sufficient to accomplish the Required Action, and takes into account the low probability of an event requiring the SRM occurring during this time.

E.1 and E,2 With one or more required SR, s irnoperable in MODE 5, the capability to detect local reactivity changes in the core during refueling is degraded, CORE ALTERATIONS M4t, be immediately suspended, and action must be immediately initiated to"nsert all insertable control rods in core cells containing one or more fuel assemblies. Suspending CORE ALTERATIONS prevents the two most probable causes of reactivity changes, fuel loading and control rod withdrawal, from occ-uning.

Inserting all insertable control rods ensures that the reactor will be at its minimum reactivity, given that fuel is present in the core. Suspension of CORE ALTERATIONS shall not preclude completion of the'movement of a component to a safe, conservative position.

Action (once required to be iniitiated) to insert control rods must continue until all insertable rods in core cells containing one or more fuel assemblies are inserted.

SURVEILLANCE The SRs for each SRM Applicable MODE or other specified condition are REQUIREMENTS found in the SRs column of Table 3.3.12-1.

SR 1.331.2.1 and SR 3.3 -23 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to the same parameter indicated on other similar channels. It is based on the assumption that instrument channels monitoring the same parameter' should read approximately Lhe same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verif',in the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

,_(continued)

RIVER BEND B 3.3-36 Revision No. 0

Attachment 4 RBG -46 690 List of Regulatory Commitments to RBG-46690 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 (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE ACTION As discussed in the notice of availability published in X Within 60 the Federal Register on November 13, 2007 for this days of TS improvement, Entergy verifies the applicability of amendment TSTF-475 to River Bend Station, Unit 1, and issuance commits to establishing TS Bases consistent with TSTF-475, Revision 1 as indicated in Attachment 4.

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