View source for RBG-47675, Response to NRC Request for Additional Information - RBS LAR to Extend Type a and Type C Test Frequencies

{{Adams
| number = ML16118A283
| issue date = 04/19/2016
| title = Response to NRC Request for Additional Information - RBS LAR to Extend Type a and Type C Test Frequencies
| author name = Maguire W
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000458
| license number = NPF-047
| contact person = 
| case reference number = LAR 2014-04, RBF1-16-0042, RBG-47675
| document type = Letter type:RBG, Response to Request for Additional Information (RAI)
| page count = 10
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:~11.G7\)1} O,:i:cml~"IB, Coo.
Rlvor Bend Station 54S51J.S. H!clW.!:ly61N St. F~villa, LA 70775 Td 226-~8Nl374
                         .,   I                                                    ITt~l~crul ~. ~~Dl)u~ro 6l::i Vica Prca!d:mt RBG-47675 April 19, 2016 U.S. Nuclear Aegufatory Commission Attn: Document Control Desk ;
Washington, DC 20555

==SUBJECT:==
Response to NAC Request for Additional Information " RBS LAff to Extend Type A and Type C Test Frequencies River Bend Station, Unit 1 Dooket No. 50-458                                             \..,
Ucense No. NPF-47 Reference 1.) Entergy Letter; License Amendment Request for change to Technical Specification; 5.5.13, to be extended to 15 years. Drywell Bypass Test Frequency to, 15 Years and Type C Test Frequency to 75 Months (RBG-
              . 47620) Dated October 29, 2015 2.) NRC email; River Bend Station, Unit 1, Request for Additional Information* ASS I.AA to Extend Type A and.Type C Test Frequencies (NEI
* 94-01, Rev. $-A) *TAC No. MF7037, Dated March 21, 2016
                    -'
* l                                    I

==Dear Sir or Madam:==

                                                        }
In Reference 1 Entergy Operations, Inc. (Entergy) submitted a request for an amendment to the Technical Specifications (TS) for River Bend Station (RBS). Unit 1. The proposed
,amendment modifies the existing requirements related tO contarnment leak rate testing.
In Reference 2 the NRC Staff requested additional Information (AAt) in support of this request.                   -
* Attachment 1 provides responses to the AAI with Attachment 2 providing revised TS
* pages. Attachment 3 includes regulatory commitments to be implemented Jn support of this change.                                                               ,

RBG-47675 Page2of3 If you have any questions or require additional fnformation, please contact Mr. J. A. Cfark at (225) 381-4177.
f declare under penalty of perjury that the foregoing is true and correct. Executed on April 19, 2016.
WFMIJAC/bm Attachments:
: 1. Response to Request for lnformdon
: 2. Proposed Technical Specification Changes (mark-up)
: 3. List of Regulatory Commitments.
co: Regional Administrator      .
: u. s. Nuclear Regulatory Commission,      Region IV 1600 East Lamar Blvd.
Arlington, TX 76011-4511 NRC Senior Resident Inspector P. O. Box 1050 St. Francisville, t..A 70775
: u. S. Nuclear Regulatory Commission Attn: Ms. Andrea George MS881A One White Fttnt North 11555 Rockville Pike Rockville, MD 20852

RBG-47675 Page3of3*
Department of Environmental Quality Office of Environmental Compliance Aadlologtcal Emergency Planning and Response Section JI Young Wiley P.O. Box 4312 Baton Rouge, LA 70821"4312 Public Utility Commission of Texas Attn: PUC Filing Clerk 1701 N. Congress Avenue o.
P. Sox 13326 Austin, TX 78711-3326 RBF1*16-0042 LAR2014-04
  \

MWihmem1 ABQ..4?6fi A~ to Reqwatfor Information
(

RBG-47675 Attachment 1 Page 1of2 By application dated October 29, 2015 (Agencywlde Documents Access and Management System (ADAMS) Accession No. ML15307A293), *Entergy Operations, Inc. (Entergy, the licensee), submitted a license amendment request (lAR) for River Bend Station. Unit 1 (RBS). The LAR would revise Technical Specification (TS) 5.5.13, "Primary Containment Leakage Rate Testing Program," to incorporate Nuclear Energy Institute (NEI) topical report 94-01, Revision 3-At *industry Guideline for Implementing Performance*Sased Option of 10 CFR Part 50, Appendix J," which woufd allow for the extension of the Type A Test (Integrated Leak Rate Test, or ILRT) and Type C Test (Local Leak Rate Test) frequencies from 10to15 years and 60 to 75 months, respectively. Surveillance Requirement (SR) S.6.5.1.3, would also be revised to extend the maximum Interval for performing the Orywelt Bypass-Test from 10 to 15 years In order to remain consistent with the proposed extended Type A Test frequency provided for in NEI 94-01 Revision S.A.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required In order to oompt&te its review of the LAR.
$CV&sect;JW..1 In Attachment 1, Section 2 ot its LAR, the licensee states that the purpose of the proposed change is to allow for the extension of the Type A Test {II.AT) frequency from 10 to 15 years. The proposed new TS 5.5.13 reads:                                     -
A program shalt be established-to Implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J.
Option B,_ as modified by approved exemptions. Thi&* program shall be in accordance with NS 94--01, Revlston-S*A, "Industry Guidelines for -
Implementing Performance-Based Option of 10 CFA Part 50, Appendix J,9 July 2012.
NEI 94-01, Revision 2*A (ADAMS Accesslon No. ML100620847), incorporated the NRC staff's corresponding Safety Evaluation Report {SEA), which included a list of limitations and conditions to be satisfied by licensees proposing to use-that topical report to extend the ILRT frequency. The subsequent revision of the topical report, NEt 94o01, Revision S*
A, referred to the previous Aevlslon 2*A in a historical discussion context, but did not.
Incorporate the Hmltationt and conditions fisted in the NRC SEA for Revision 2*A. fn a letter dated August 20, 2013 (ADAMS Accession No. ML13192A394)t the NRC staff informed NEI that any licensee submissions referencing NEI 94-01, Revision 3-A will require requests for additional* information to address the Hmftations and conditions In the NRC SER for NEI 94-01, Revision 2*A. In other words, a reference to NEI 94-01, Revision 3-A by Itself would not be a sufficient TS reference to a guidance document by for allowtng an extension to the Type A Test frequency to 15 years.
Please describe how, without referencing the limitations and conditions from NEI 94-01 Revision 2*A in the TS, a reference to NEI 94-01, Revision 3-A. would be sufficient to support the extension of the Type A test frequency.
BU&DB , Table 4.0- 1 of the submittal, addressed the conditions and limitations In NEI 94-01 Revision 2*A Section 4.1. To address the concem that these conditions and

RBG-47675 Attachment 1 Page2of 2 limitations would be maintained, Entergy proposes the addition of specifie reference to NEI 94-01 Revision 2*A Section 4.1 as described batow. .
Proposed revision; A program shall be *bHshed to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, ()ptlon 8, as modified by approved exemptions. This program shall be In accordance with the guidelines contained In NEI 94-01, *industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J," Revision 3-A, dated Jury 201.2, IDS&
th@ conditigns and llmitatJOQS specjffgd In NEI 94:Q1. BJ.vi!jon,,g-A, Se!flkm 4.J. dfigl 0ct9b* gpoa.                                                      .
SCVBBAl*2 In its LAR, the ~lcensee proposes to revise the Note In SR S.6.6.1.3 to state that "SR 3.0.2 Is not applicable for extensions > 9 months." In Its I.AR, the tlcensee states that the request to extend the Drywell Bypass Test frequency from to to 15 years Is in farge part to align it with performance of the tLRT (i.e., perform both tests in the same refueffng outage) in order to reduce costs and radlological dose. The risk evaluation proVfded in the LAR assumes both the Drywetl Bypass Test and the ILAT are performed on a 15 year Interval, further Indicating that both tests would be performed during ti1e same timeframe.
The NEI 94-01, Revision 2*A, NRC staff SEA limitations and conditions Include a provision that the 15-year Type A Test interval only be exceeded upon demonstration to the NRC staff that exceeding the 15 year interval is due to an unforeseen emergent condition.                            *
* Please provide Justification as to why SR 3.8.5.1.3 retains an extension option for the proposed 180-month DryweH Bypass Test frequency, which Is not subject to the same condition as that of the corresponding ILRT frequency. as discussed above.
BIUoDIA , Section 4 of the submittal discusses the proposed revision of the Drywell Bypass test (DWBT) frequency to align with the praposed ILRT frequency. To address the concem that extensions cou~ be used for operattonat convenience Entergy proposes that add'rtionat dlecusslon be added to the BASES as described below.
The following will be added to th.e BASES of SR 3.6.5.1.3;
    ,                               I The provlSlon to extend this lntesval Is not Intended to be used as an operational convenience. Extensions are subject to the same condition as that of the corresponding !LAT frequency.

Attachment I RBCW7875 Propoaed Technlc81 Specffintlon Changea(mark-up)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11       Technical Specifications (TS) Bases Control Program (continued)
: c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the USAR.
: d. Proposed changes that do not meet the criteria of either Specification 5.5.11.b.1 or Specification 5.5.11.b.2 above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).
5.5.12       DELETED 5.5.13       Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance Based Containment Leak Test Program," dated September 1995, except that the next Type A test performed after the August 15, 1992, Type A test shall be performed no later than April 14, 2008. NEI 94-01. "Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J." Revision 3-A. dated July 2012. and the conditions and limitations specified in NEI 94-01. Revision 2-A.
Section 4.1. dated October 2008.
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 7.6 psig.
The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.325% of primary containment air weight per day.
The Primary Containment leakage rate acceptance criterion             is~ 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are ~ 0.60 La for the Type B and Type C tests and~    0.75 La for Type A tests.
The provisions of SR 3.0.2 do not apply to test frequencies specified in the Primary Containment Leakage Rate Testing Program.
The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.
5.5.14       Control Room Envelope Habitabilitv Program RIVER BEND                                  5.0-16 Amendment No. 81 84 95 131 132 150 154, 155

Attachment 3 RBCM78'11 List of Rtptatory COmmitmentt

RBG*47675 Attaehment 3 Page 1of1 l
Lilt of Regulatofy COmmltmenta The following tabla 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
{ChftkOM)          SCHEDUL.ID unc-     CONTINUING      COMPLITION CO&*MITMENT
                                                        --TIM&--  COMPLIANCE          DATE The following witf be added to the BASES of SA              )(                        Upon 3.6.5.1.3:                                                                       Implementation The provlSton to eJdend thts lntervat Is not Intended to be used as an operational convenfenQe. Extensions are sublect to the                                    '
same eonditlon as that of the
   .. corresponding ILAT frequency*

                                                                                   ~11.G7\)1} O,:i:cml~"IB, Coo.
Rlvor Bend Station 54S51J.S. H!clW.!:ly61N St. F~villa, LA 70775 Td 226-~8Nl374
                         .,   I                                                    ITt~l~crul ~. ~~Dl)u~ro 6l::i Vica Prca!d:mt RBG-47675 April 19, 2016 U.S. Nuclear Aegufatory Commission Attn: Document Control Desk ;
Washington, DC 20555

==SUBJECT:==
Response to NAC Request for Additional Information " RBS LAff to Extend Type A and Type C Test Frequencies River Bend Station, Unit 1 Dooket No. 50-458                                             \..,
Ucense No. NPF-47 Reference 1.) Entergy Letter; License Amendment Request for change to Technical Specification; 5.5.13, to be extended to 15 years. Drywell Bypass Test Frequency to, 15 Years and Type C Test Frequency to 75 Months (RBG-
              . 47620) Dated October 29, 2015 2.) NRC email; River Bend Station, Unit 1, Request for Additional Information* ASS I.AA to Extend Type A and.Type C Test Frequencies (NEI
* 94-01, Rev. $-A) *TAC No. MF7037, Dated March 21, 2016
                    -'
* l                                    I

==Dear Sir or Madam:==

                                                        }
In Reference 1 Entergy Operations, Inc. (Entergy) submitted a request for an amendment to the Technical Specifications (TS) for River Bend Station (RBS). Unit 1. The proposed
,amendment modifies the existing requirements related tO contarnment leak rate testing.
In Reference 2 the NRC Staff requested additional Information (AAt) in support of this request.                   -
* Attachment 1 provides responses to the AAI with Attachment 2 providing revised TS
* pages. Attachment 3 includes regulatory commitments to be implemented Jn support of this change.                                                               ,

RBG-47675 Page2of3 If you have any questions or require additional fnformation, please contact Mr. J. A. Cfark at (225) 381-4177.
f declare under penalty of perjury that the foregoing is true and correct. Executed on April 19, 2016.
WFMIJAC/bm Attachments:
: 1. Response to Request for lnformdon
: 2. Proposed Technical Specification Changes (mark-up)
: 3. List of Regulatory Commitments.
co: Regional Administrator      .
: u. s. Nuclear Regulatory Commission,      Region IV 1600 East Lamar Blvd.
Arlington, TX 76011-4511 NRC Senior Resident Inspector P. O. Box 1050 St. Francisville, t..A 70775
: u. S. Nuclear Regulatory Commission Attn: Ms. Andrea George MS881A One White Fttnt North 11555 Rockville Pike Rockville, MD 20852

RBG-47675 Page3of3*
Department of Environmental Quality Office of Environmental Compliance Aadlologtcal Emergency Planning and Response Section JI Young Wiley P.O. Box 4312 Baton Rouge, LA 70821"4312 Public Utility Commission of Texas Attn: PUC Filing Clerk 1701 N. Congress Avenue o.
P. Sox 13326 Austin, TX 78711-3326 RBF1*16-0042 LAR2014-04
  \

MWihmem1 ABQ..4?6fi A~ to Reqwatfor Information
(

RBG-47675 Attachment 1 Page 1of2 By application dated October 29, 2015 (Agencywlde Documents Access and Management System (ADAMS) Accession No. ML15307A293), *Entergy Operations, Inc. (Entergy, the licensee), submitted a license amendment request (lAR) for River Bend Station. Unit 1 (RBS). The LAR would revise Technical Specification (TS) 5.5.13, "Primary Containment Leakage Rate Testing Program," to incorporate Nuclear Energy Institute (NEI) topical report 94-01, Revision 3-At *industry Guideline for Implementing Performance*Sased Option of 10 CFR Part 50, Appendix J," which woufd allow for the extension of the Type A Test (Integrated Leak Rate Test, or ILRT) and Type C Test (Local Leak Rate Test) frequencies from 10to15 years and 60 to 75 months, respectively. Surveillance Requirement (SR) S.6.5.1.3, would also be revised to extend the maximum Interval for performing the Orywelt Bypass-Test from 10 to 15 years In order to remain consistent with the proposed extended Type A Test frequency provided for in NEI 94-01 Revision S.A.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required In order to oompt&te its review of the LAR.
$CV&sect;JW..1 In Attachment 1, Section 2 ot its LAR, the licensee states that the purpose of the proposed change is to allow for the extension of the Type A Test {II.AT) frequency from 10 to 15 years. The proposed new TS 5.5.13 reads:                                     -
A program shalt be established-to Implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J.
Option B,_ as modified by approved exemptions. Thi&* program shall be in accordance with NS 94--01, Revlston-S*A, "Industry Guidelines for -
Implementing Performance-Based Option of 10 CFA Part 50, Appendix J,9 July 2012.
NEI 94-01, Revision 2*A (ADAMS Accesslon No. ML100620847), incorporated the NRC staff's corresponding Safety Evaluation Report {SEA), which included a list of limitations and conditions to be satisfied by licensees proposing to use-that topical report to extend the ILRT frequency. The subsequent revision of the topical report, NEt 94o01, Revision S*
A, referred to the previous Aevlslon 2*A in a historical discussion context, but did not.
Incorporate the Hmltationt and conditions fisted in the NRC SEA for Revision 2*A. fn a letter dated August 20, 2013 (ADAMS Accession No. ML13192A394)t the NRC staff informed NEI that any licensee submissions referencing NEI 94-01, Revision 3-A will require requests for additional* information to address the Hmftations and conditions In the NRC SER for NEI 94-01, Revision 2*A. In other words, a reference to NEI 94-01, Revision 3-A by Itself would not be a sufficient TS reference to a guidance document by for allowtng an extension to the Type A Test frequency to 15 years.
Please describe how, without referencing the limitations and conditions from NEI 94-01 Revision 2*A in the TS, a reference to NEI 94-01, Revision 3-A. would be sufficient to support the extension of the Type A test frequency.
BU&DB , Table 4.0- 1 of the submittal, addressed the conditions and limitations In NEI 94-01 Revision 2*A Section 4.1. To address the concem that these conditions and

RBG-47675 Attachment 1 Page2of 2 limitations would be maintained, Entergy proposes the addition of specifie reference to NEI 94-01 Revision 2*A Section 4.1 as described batow. .
Proposed revision; A program shall be *bHshed to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, ()ptlon 8, as modified by approved exemptions. This program shall be In accordance with the guidelines contained In NEI 94-01, *industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J," Revision 3-A, dated Jury 201.2, IDS&
th@ conditigns and llmitatJOQS specjffgd In NEI 94:Q1. BJ.vi!jon,,g-A, Se!flkm 4.J. dfigl 0ct9b* gpoa.                                                      .
SCVBBAl*2 In its LAR, the ~lcensee proposes to revise the Note In SR S.6.6.1.3 to state that "SR 3.0.2 Is not applicable for extensions > 9 months." In Its I.AR, the tlcensee states that the request to extend the Drywell Bypass Test frequency from to to 15 years Is in farge part to align it with performance of the tLRT (i.e., perform both tests in the same refueffng outage) in order to reduce costs and radlological dose. The risk evaluation proVfded in the LAR assumes both the Drywetl Bypass Test and the ILAT are performed on a 15 year Interval, further Indicating that both tests would be performed during ti1e same timeframe.
The NEI 94-01, Revision 2*A, NRC staff SEA limitations and conditions Include a provision that the 15-year Type A Test interval only be exceeded upon demonstration to the NRC staff that exceeding the 15 year interval is due to an unforeseen emergent condition.                            *
* Please provide Justification as to why SR 3.8.5.1.3 retains an extension option for the proposed 180-month DryweH Bypass Test frequency, which Is not subject to the same condition as that of the corresponding ILRT frequency. as discussed above.
BIUoDIA , Section 4 of the submittal discusses the proposed revision of the Drywell Bypass test (DWBT) frequency to align with the praposed ILRT frequency. To address the concem that extensions cou~ be used for operattonat convenience Entergy proposes that add'rtionat dlecusslon be added to the BASES as described below.
The following will be added to th.e BASES of SR 3.6.5.1.3;
    ,                               I The provlSlon to extend this lntesval Is not Intended to be used as an operational convenience. Extensions are subject to the same condition as that of the corresponding !LAT frequency.

Attachment I RBCW7875 Propoaed Technlc81 Specffintlon Changea(mark-up)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11       Technical Specifications (TS) Bases Control Program (continued)
: c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the USAR.
: d. Proposed changes that do not meet the criteria of either Specification 5.5.11.b.1 or Specification 5.5.11.b.2 above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).
5.5.12       DELETED 5.5.13       Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance Based Containment Leak Test Program," dated September 1995, except that the next Type A test performed after the August 15, 1992, Type A test shall be performed no later than April 14, 2008. NEI 94-01. "Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J." Revision 3-A. dated July 2012. and the conditions and limitations specified in NEI 94-01. Revision 2-A.
Section 4.1. dated October 2008.
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 7.6 psig.
The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.325% of primary containment air weight per day.
The Primary Containment leakage rate acceptance criterion             is~ 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are ~ 0.60 La for the Type B and Type C tests and~    0.75 La for Type A tests.
The provisions of SR 3.0.2 do not apply to test frequencies specified in the Primary Containment Leakage Rate Testing Program.
The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.
5.5.14       Control Room Envelope Habitabilitv Program RIVER BEND                                  5.0-16 Amendment No. 81 84 95 131 132 150 154, 155

Attachment 3 RBCM78'11 List of Rtptatory COmmitmentt

RBG*47675 Attaehment 3 Page 1of1 l
Lilt of Regulatofy COmmltmenta The following tabla 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
{ChftkOM)          SCHEDUL.ID unc-     CONTINUING      COMPLITION CO&*MITMENT
                                                        --TIM&--  COMPLIANCE          DATE The following witf be added to the BASES of SA              )(                        Upon 3.6.5.1.3:                                                                       Implementation The provlSton to eJdend thts lntervat Is not Intended to be used as an operational convenfenQe. Extensions are sublect to the                                    '
same eonditlon as that of the
   .. corresponding ILAT frequency*
                                           '}}