RBG-47925, Supplement to Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)

Supplement to Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)

ML19002A115
Person / Time
Site:	River Bend
Issue date:	12/20/2018
From:	Reynolds J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBF1-18-0240, RBG-47925
Download: ML19002A115 (21)

Text

~Entergy Entergy Operations, Inc.

5485 U.S . Highway 61 N St. Francisville, LA 70775 Jeff W. Reynolds Director, Regulatory Assurance River Bend Station T 91. (225) 635-5000 K&~\-l ~~ O'd40 10 CFR 50.90 RBG-47925 December 20,2018 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Supplement to Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)

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

References:

1) Entergy Operations, Inc. letter to U. S. Nuclear Regulatory Commission "Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control," dated November 15, 2017. (ML17319A898)

2) Entergy Operations, Inc. letter to U. S. Nuclear Regulatory Commission, "Application for Technical Speci'fication Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency requirements to a Licensee Controlled Program (TSTF-425)," dated February 28,2018. (ML18067A115)

3) Nuclear Regulatory Commission to Entergy Operations, Inc. "River Bend Station, Unit 1 - Issuance of Amendment RE: Revision to Technical Specifications to Adopt TSTF-S42, Revision 2, Reactor Pressure Vessel Water Inventory Control," dated November 7, 2018. (ML18267A341)

Dear Si r or Madam,

On November 15, 2017 Entergy Operating, Inc. (Entergy) submitted a License Amendment Request (LAR) to adopt Technical Specification Task Force 542 (TSTF-542) at River Bend Station (RBS). (Reference 1)

RSG-47925 Page 2 of 3 On February 28,2018, Entergy submitted an LAR to adopt TSTF-425 at RSS. (Reference 2)

On November 7,2018 the U.S Nuclear Regulatory Commission (NRC) issued Amendment 193 (Reference 3) to the RSS Technical Specifications (TS) approving the implementation of TSTF-542. Issuance of Amendment 193 modified pages to the RSS TS that were submitted to the NRC in the TSTF-425 LAR. This letter supplements the original submittal of TSTF-425 LAR to:

1. Include new surveillances added to the RSS TS as a result of Amendment 193.

2. Update the text of surveillances whose language was modified as a result of Amendment 193.

3. Update the text of Conditions, Required Actions, and Completion Times that were modified by Amendment 193.

4. Update changes that were made as a result of TS content moving from one page to another from the addition or deletion of TS content as a result of Amendment 193.

5. Update changes to surveillance numbers that were made as a result of Amendment 193.

6. Update TS section title changes that were made as a result of Amendment 193.

TS page 3.5-7 of the original TSTF-425 LAR should be discarded. The changes submitted on TS page 3.5-7 have moved to page 3.5-8 as a result of Amendment 193 and are presented in the attachments to this letter.

This supplement letter also corrects an error identified in the original submittal of the TSTF-425 LAR. Page 3.3-4 was mistakenly labeled 3.3-5. The Amendment numbers on page 3.3-4 are also corrected in this supplement letter.

Entergy has determined that relocating the frequency of SRs added to, or modified from, the original TSTF-425 LAR identified in this supplement is consistent with TSTF-425, Revision 3; and with the NRC staffs model Safety Evaluation dated July 6, 2009 including the scope exclusions identified in the model Safety Evaluation.

Specifically, these surveillance frequencies are not:

1. Frequencies that reference other approved programs for the specific interval (such as the Inservice Testing Program or the Primary Containment Leakage Rate Testing Program).

2. Frequencies that are purely event driven (e.g., "Each time the control rod is withdrawn to the 'full out' position") .

3. Frequencies that are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after thermal power reaching 95% RTP").

RBG-47925 Page 3 of 3

4. Frequencies that are related to specific conditions (e.g., battery degradation, age, and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywall to suppression chamber differential pressure decrease").

Changes to the frequency for these surveillances will be controlled under the Surveillance Frequency Control Program (SFCP) in accordance with TSTF-425. The SFCP provides the necessary administrative controls to ensure that surveillances related to testing, calibration, and inspection are conducted at a frequency necessary to assure the quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Furthermore, TSTF-542 recognizes that the SFCP is acceptable for use in each SR that this supplement identHies as added to, or modified from, the original TSTF-425 LAR. contains a markup of TS pages 'from the original TSTF-425 LAR that were modified by Amendment 193 and the page number correction for TS page 3.3-4. contains the clean TS pages of the original TSTF-425 LAR with Amendment 193 incorporated and the page number correction for TS page 3.3-4.

Entergy has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Reference 2. The information provided in this submittal does not affect the basis for concluding that the proposed license amendment does not involve a significant hazards consideration.

There are no regulatory commitments contained within this letter.

Should you have any questions or require additional information, please contact Timothy Schenk at 225-381-4177 .

Je JWR/twf : Markup of TS Pages from original TSTF-425 LAR. : Clean TS Pages.

cc: NRC Region IV Regional Administrator, w/o Enclosure NRC Senior Resident Inspector - River Bend Station, Unit 1 Ji Young Wiley, Department of Environmental Quality, Office of Environmental Compliance, Radiological Emergency Planning and Response Section Public Utility Commission of Texas, Attn: PUC Filing Clerk NRC Project Manager

AITACHMENTI Markup of TS Pages from original TSTF-425 lAR

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.4 ----------------- ----------- --I\J 0 T E----------------------------

Not required to be periormed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 2.

Periorm CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1 .5 Periorm CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.6 Verify the source range monitor (SRM) and Prior to intermediate range monitor (IRM) channels withdrawing SRMs overlap. from the fully inserted position SR 3.3.1.1.7 -------- -- ------- -- -- ------- -- NOT E--------- -- ----- -- -- -- -- ----

Only required to be met during entry into MODE 2 from MODE 1.

Verify the IRM and APRM channels overlap. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.8 Calibrate the local power range monitors. In acco rdance with the Surveillance Frequency Control Program (continued)

~ 1110IlT I RIVER BEND 3.3-5 Amendment No. 81 106 114, 1-68 I

RCIC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

---

NOT E S -----------------------------------------------------------

1. Refer to Table 3.3.5.3-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delay.ed as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 2 and 5; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 1, 3, and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.3 .1 Perform CHANNEL CHECK. f.2.

SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. 92 says .-.../

SR 3.3.5 .3.3 Calibrate the trip units. 92 says ./

SR 3.3.5.3.4 Perform CHANNEL CALIBRATION . ~ "-

SR 3.3.5.3.5 Perform LOGIC SYSTEM FUNCTIONAL TES T . 24-ffi*cmifls ./

In accordance with the Surveillance Frequency Control Program RIVER BEND 3.3-46 Amendment No . 81 , 168, f-9.3 I

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME is ~ 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

SR 3.5.2.2 Verify, for a required low pressure ECCS ~eHFS ./

injection/spray subsystem, the suppression po 01 water level is ~ 13 ft 3 inches.

SR 3.5.2 .3 Verify, for the required High Pressure Core Sp ray 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> L (HPCS) System, the:

a. Suppression pool water level is ~ 13 ft 3 in ches; or

b. Condensate storage tank water level is ~ 1 1 ft 1 inch.

SR 3.5.2.4 Verify, for the required ECCS injection/spray 31- Gays ./

subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.2.5 -------------------------------NOT ES-----------------------------

1. A low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay h eat removal, if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flow paths opened under administrative control.

Verify, for the required ECCS injection/spray 34-Gays

./

subsystem, each manual, power operated, and automatic valve in the flow path, that is not loc ked, sealed, or otherwise secured in position, is in t he correct position.

(continued)

In accordance with the Surveillance Frequency 1-Control Program RIVER BEND 3.5-8 Amendment No. &i, ~, 493 I

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued SURVEILLANCE FREQUENCY SR 3.5.2.6 Operate the required ECCS injection/spray 92-.. aays ~

subsystem for ~ 10 minutes SR 3.5.2.7 Verify each valve credited for automatically isolating 24 Ffl8AtAS ./

a penetration flow path actuates to the isolation "

position on an actual or simulated actuation signal.

SR 3.5.2.8 -----------------------------NOT E--------------------------------

Vessel injection/spray may be excluded.

Verify the required LPCI or LPCS subsystem 24 Ffl8AtAS ",.,-

actuates on a manual initiation signal, or the required HPCS subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program RIVER BEND 3.5-9 Amendment No. 3-i, +98, 4e.3 I

CRFA System 3.7.2 ACTIOI\JS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CRFA subsystems F.1 Suspend movement of recently Immediately inoperable during irradiated fuel assemblies in the movement of recently primary containment and fuel irradiated fuel assemblies building.

in the primary containment or fuel building.

One or more CRFA subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel building .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Operate each CRFA subsystem f or z 15 continuous 31-eay-s /"

minutes.

SR 3.7.2.2 Perform required CRFA filter testi ng in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.2.3 Verify each CRFA subsystem act uates on an actual 24-fHSA-tAs ./

or simulated initiation signal.

(continued)

In accordance with the Surveillance Frequency Control Program RIVER BEND 3.7-7 Amendment No. 81 119 132 154

~~~49d I

Control Room AC System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Suspend movement of recently Immediately associated Completion irradiated fuel assemblies in the Time of Condition B not primary containment and fuel met during movement of building.

recently irradiated fuel assemblies in the primary containment or fuel building.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify each control room AC subsystem has the 24 FR9R#ls <

capability to remove the assumed heat load.

In accordance with the Surveillance Frequency Control Program RIVER BEND 3.7-11 Amendment No. 81 119 132 , ~, +W

Inve rters-S h utdown 3.8.8 ACTIOI\JS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage, frequency, and 1-aays ./

alignments to required AC vital buses.

In accordance with the Surveillance Frequency Control Program RIVER BEND 3.8-37 Amendment No. 84-, 1-9-3 I

Distribution Systems-Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate actions to restore Immediately required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

A.2.4 Declare associated required shutdown cooling Immediately subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and voltage to 7 days /'

required AC, DC, and AC vital bus electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program RIVER BEND 3.8-42 Amendment No . S+, +B-3 I

ATTACHMENT 2 Clean T5 Pages

RPS Instrumentation 3.3.1.1 SURVEILLANCE REOUIREMEI\ITS (continued)

SURVEILLANCE FREOUEI\JCY SR 3.3.1.1.4 ------------------------------ NOT E----------------------------

Not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1 .5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.6 Verify the source range monitor (SRM) and Prior to intermediate range monitor (I RM) channels withdrawing SRMs overlap. from the fully inserted position SR 3.3.1.1.7 ------------------------------ NOT E--- ----------------- --------

Only required to be met during entry into MODE 2 from MODE 1.

Verify the IRM and APRM channels overlap. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.8 Calibrate the local power range monitors. In accordance with the Surveillance Frequency Control Program (continued)

RIVER BEND 3.3-4 Amendment No. 8+, -+00, .we, +W, ++4,

RCIC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

---

NOT ES -----------------------------------------------------------

1. Refer to Table 3.3.5.3-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 2 and 5; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 1, 3, 'and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5 .3.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.3 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program RIVER BEND 3.3-46 Amendment No. 81, 168, +9J I

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREIVIENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME is 2: 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure ECCS In accordance with injection/spray subsystem, the suppression pool the Surveillance water level is ~ 13 ft 3 inches. Frequency Control Program SR 3.5.2.3 Verify, for the required High Pressure Core Spray In accordance with (HPCS) System, the: the Surveillance Frequency Control

a. Suppression pool water level is ~ 13 ft 3 inches; Program or

b. Condensate storage tank water level is ~ 11 ft 1 inch.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently 'filled with water. Frequency Control Program SR 3.5.2.5 ------------------- ------------ NOT E S-----------------------------

1. A low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flow paths opened under administrative control.

Verify, for the required ECCS injection/spray In accordance with subsystem, each manual, power operated, and the Surveillance automatic valve in the flow path, that is not locked, Frequency Control sealed, or otherwise secured in position, is in the Program correct position .

(continued)

RIVER BEND 3.5-8 Amendment No. &+, +88, +9d I

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Operate the required ECCS injection/spray In accordance with subsystem for 2: 10 minutes. the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating In accordance with a penetration flow path actuates to the isolation the Surveillance position on an actual or simulated actuation signal. Frequency Control Program SR 3.5.2.8 ----------------------------- N0 -r E-- ------------------------------

Vessel injection/spray may be excluded.

Verify the required LPCI or LPCS subsystem In accordance with actuates on a manual initiation signal, or the required the Surveillance HPCS subsystem can be manually operated. Frequency Control Program RIVER BEND 3.5-9 Amendment No. &+, -+@, ~

CRFA System 3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CRFA subsystems F.1 Suspend movement of recently Immediately inoperable during irradiated fuel assemblies in the movement of recently primary containment and fuel irradiated fuel assemblies building.

in the primary containment or fuel building.

OR One or more CRFA subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel building.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Operate each CRFA subsystem for ~ 15 continuous In accordance with minutes. the Surveillance Frequency Control Program SR 3.7.2.2 Peliorm required CRFA filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.2.3 Verify each CRFA subsystem actuates on an actual In accordance with or simulated initiation signal. the Surveillance Frequency Control Program (continued)

RIVER BEND 3.7-7 Amendment No. 81 11 9 132 154 I

+ea +e8, ~ 9d

Control Room AC System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Suspend movement of recently Immediately associated Completion irradiated fuel assemblies in the Time of Condition B not primary containment and fuel met during movement of building.

recently irradiated fuel assemblies in the primary containment or fuel building.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify each control room AC subsystem has the In accordance with capability to remove the assumed heat load. the Surveillance Frequency Control Program RIVER BEND 3.7-11 Amendment No. 81 11 9 132, +W, +9d I

Inverters-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage, frequency, and In accordance with alignments to required AC vital buses. the Surveillance Frequency Control Program RIVER BEt\ID 3.8-37 Amendment No. ~, +9d I

Distribution Systems-Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate actions to restore Immediately required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

AND A.2.4 Declare associated required shutdown cooling Immediately subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and voltage to In accordance with required AC, DC, and AC vital bus electrical power the Surveillance distribution subsystems. Frequency Control Program RIVER BEND 3.8-42 Amendment No. 8+, +9a