JAFP-07-0023, Application for Amendment to Technical Specifications 3.10.1. Re Inservice Leak and Hydrostatic Testing Operation, Consistent with TSTF-484

Application for Amendment to Technical Specifications 3.10.1. Re Inservice Leak and Hydrostatic Testing Operation, Consistent with TSTF-484

ML070871160
Person / Time
Site:	FitzPatrick
Issue date:	02/15/2007
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-07-0023
Download: ML070871160 (15)

Text

Admbýl Entergy Nuclear Northeast Alý Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP MW EnteW P.O. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 Pete Dietrich Site Vice President - JAF February 15, 2007 JAFP-07-0023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Application for Amendment to Technical Specifications 3.10. L.: Inservice Leak and Hydrostatic Testine Operation, Consistent with TSTF-484 Gentlemen:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) hereby requests an amendment to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed amendment would revise TS Section 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," to expand its scope to include provisions for temperature excursions greater than 212 'F as a consequence of inservice leak or hydrostatic testing, and to allow performance of control rod scram time testing and other required testing when initiated in conjunction with the performance of an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. The changes are consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

Attachment I provides a description and evaluation of the proposed TS changes.

Attachment 2 provides the proposed changes to the current TS on marked up pages.

Attachment 3 provides the proposed changes in final typed format.

Attachment 4 provides the proposed changes to the current TS Bases on marked up pages. The Bases changes are provided for NRC information only. The final TS Bases pages will be submitted with a future update in accordance with TS 5.5.11, "Technical Specifications (TS)

Bases Control Program".

Entergy requests NRC approval of the proposed TS amendment by February 28, 2008, with the amendment being implemented within 30 days from approval.

JAFP-07-0023 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this application, with the associated attachments, is being provided to the designated New York State official.

There are no commitments contained in this letter.

Should you have any questions concerning this submittal, please contact Mr. Jim Costedio at 315-349-6358.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the I /y o February, 2007.

Peee D trich Site Vice President PDftp Attachments: 1. Description and evaluation of the proposed TS changes

2. Proposed changes to the current TS on marked up pages

3. Proposed changes in final typed format

4. Proposed changes. to the current TS Bases on marked up pages cc: next page

cc:

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415.

Resident Inspector's Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. John P. Boska, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10 Floor Albany, NY 12223 Mr. Peter R. Smith, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399

JAFP-07-0023 Attachment 1 Description and Evaluation Application for Amendment to Technical Specifications 3.10.1, Inservice Leak and Hydrostatic Testing Operation, Consistent with TSTF-484

JAFP-07-0023 Attachment 1 1.0 Description The existing James A. FitzPatrick Nuclear Power Plant (JAF) Technical Specifications (TS) Section 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," allows the average reactor coolant system (RCS) temperature to exceed 212 *F as a consequence of maintaining pressure during an inservice leak or hydrostatic test. The proposed amendment would revise TS 3.10.1 to expand its scope to include provisions for temperature excursions greater than 212 'F as a consequence of inservice leak or hydrostatic testing, and to allow performance of control rod scram time testing and other required testing when initiated in conjunction with the performance of an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. A temperature value of 212 'F is used in the JAF TS vs. the bracketed value of 200 *F in NUREG-1433, Standard Technical Specifications General Electric Plants, BWR/4.

The changes are consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

2.0 Proposed Changes Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, "Inservice Leak and Hydrostatic Testing Operation."

Proposed revisions to the TS Bases are also included inthis application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS amendment. The copies of the TS Bases pages are provided for NRC information.

The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program. This application is being made in accordance with the CLIIP. Entergy Nuclear Operations, Inc. (Entergy) is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

3.0 Background

The background for this application is adequately addressed by the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

Page 1 of 2

JAFP-07-0023 Attachment 1 4.0 Technical Analysis Entergy has reviewed the safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. Entergy has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to JAF and therefore justify this amendment for the incorporation of the proposed changes to the JAF TS.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Entergy has reviewed the no significant hazards determination published on August 21, 2006 (71 FR 48561) as part of the CLIIP Notice for Comment. The no significant hazards determination was made available on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. Entergy has concluded that the determination presented in the notice is applicable to JAF and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

5.2 Applicable Regulatory Requirements / Criteria A description of the proposed TS changes and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

6.0 Environmental Assessment Entergy has reviewed the environmental evaluation included in the safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

Entergy has concluded that the staff's findings presented in that evaluation are applicable to JAF and the evaluation is hereby incorporated by reference for this application.

7.0 References

1. Federal Register Notice, Notice of Availability of Model Safety Evaluation published on October 27, 2006 (71 FR 63050).

2. Federal Register Notice, Notice for Comment published on August 21, 2006 (71 FR 48561).

3. TSTF-484 Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities."

4. Federal Register Notice, Notice of Availability of Model Application published on November 27, 2006 (71 FR 68642).

Page 2 of 2

JAFP-07-0023 Attachment 2 Proposed Technical Specification Changes (Mark up)

Page 3.10.1-1

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8. "Residual Heat Removal (RHR) Shutdown Cooling System-Co dShLit ow. a be-s d o 1 provi e e oT o-wngi s are me

a. LCO 3.3.6.2. *Secondary Containment Isolation Instrumentation." Functions 1.3. and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1. "Secondary Containment";

c. LCO 3.6.4.2. 'Secondary Containment Isolation Valves (SCIVs)"; and

d. LCO 3.6.4.3. "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212 0 F.

,. For performance of an i.nservice leak or hydrostatic test,. .... (

• As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test., or e As a consequence of maintaining adequate pressure for control rod scram

• time testing initiated in conjunction with an inservice leak or hydrostatic test, JAFNPP 3.10.1-1 Amendment 474-

JAFP-07-0023 Attachment 3 Proposed Technical Specification Changes (Final Typed)

Page 3.10.1-1

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System--Cold Shutdown," may be suspended to allow reactor coolant temperature > 212 °F:

• For performance of an inservice leak or hydrostatictest,

" As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or

" As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation,"

Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)";

and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 2120 F.

JAFNPP 3.10.1-1 Amendment

JAFP-07-0023 Attachment 4 Proposed Technical Specification Bases Changes (Information Only)

Pazes B 3.10.1-1 B 3.10.1-2 B 3.10.1-3 Inserts Page

Inservice Leak and Hydrostatic Testing Oeration B3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 2127F (normally corresponding to MODE 3)0 Inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are.performed prior to the reactor going critical after a refueling outage. Recirculation pump operation, decay heat and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.9. "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits."

These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure.

Periodic updates to the RCS P/T limit curves are performed as necessary, based upon the results of analyses of .

irradiated surveillance specimens removed from the vessel.

• APPLICABLE thereactor to be considered in MODE oom---

SAFETY ANALYSES _=1 . - j when the reactor c e is > _ ,fe ectively provides an exception to 3 require ints, including OPERABILITY of primary e~ ~-r conainmet.an the full complem of redundant &ergency Core Cooling Systems. Since the h-+Ej. ýtests are performed nearly water solid, a ow ecayea-tvalues, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LCO 3.4.6, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling-any airborne radioactivity or steam leaks that could occur (continued)

JAFNPP B 3.10.1-1 Revision 9'

Inservice Leak and Hydrostatic Testing Operation E 3.10.1 BASES APPLICABLE during the performance of hydrostatic or leak testing. The SAFETY ANALYSES required pressure testing conditions provide adequate (continued) assurance that the consequences of a recirculation line break (Refs. 2 and 3) will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 4. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system leak, the reactor vessel would rapidly depressurize. allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS-Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs. in addition to the secondary containment requirements required to be met by this Special Operations LCO. will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) (Ref. 5) apply. Special Operations LCOs provide flexibility to per orm certain o erations by appropriately modifying requirements of other £COs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7. compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures

> 2127F, while performance of inservice leak and hydrostatic testing results in inoperability of subsystems required when (continued)

JAFNPP B 3.10.1-2 Revision Y

Inservice Leak and Hydrostatic Testing 0 eration

-rv C11e r scra r -b n ý ý S 1ýB 3 n *L)1-e BASES C LCO If it is desired to perform these tests while complying with (continued) this Special 0perations LCO, u t then b me thet .

MODE c i al Thi s4 Sapplicable p'e LCOs an d s p ec i f i ed O E 3 L*

l o s c a g n ale 1.1~ - 1l temperature_

Operations LC

" a d u p n i g t edow rquire ments of limits fo r O E 4 tl N e t R m va H R hut nCooling LCO 3.4. 8a " e i u d t oal requirements _fo r System - Cold Shutdown ." T e a temperatures sufficient co t i m n Cs t e m t w l rovide secondary protecto~~

performing ~an inservice

> 212"F for the purpose of leak or hydrostatic test*j to be open for frequent This LCO allows primary containment inspections, and for outage unobstructed access to perform to continue con i e llwith activities on various systems for the may only be modified The MODE 4 requirements APPLICABILITY or hydrostatic tests sgo that."-"/

p ~~~~erformance of inservice leak as in MODE 4, even thou h

• operations can be considered in t.* r &s &. *"ese The additionaI is > 212"F. conservatism

\ * .... ... ce the reactor coolant temperature containment provides OPERABILITY according

• 'e requirement forMODE secondary 3 requirements Cn*h imposed to the this LCO.

by occur.

of the plant to MODES are any event that may unaffected the responsein all other Operations to to modify the ACTIONS related A Note has been provided ACTIO1S testing operation.

inservice leak and hydrostatic specifies that once a Section 1.3, Completion Times, divisions, Condition has been entered, subsequentexpressed in the subsystems, components, or variables inoperable or not within limits, Condition discovered to be thatRequired Actions Condition.

of the separate entry into the will Section not 1.3 also inspecifies result the entry intofailure, applyon to based each additional for initial Condition continue Times or each with Completion the Required Actions Condition. ofhowever, the LCO not met provide appropriate are not that requirement for separate requirements separate measures that allows compensatory a Note has been provided LCO.

met. As such, for each requirement ofthe Condition entry (continued)

JAFNPP B 3.10.1-3 Revision Y

JAFP-07-0023 TS Bases 3.10.1 Inserts INSERT 1 or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 212°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212'F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.

INSERT 2 However, even with required minimum reactor coolant temperatures < 212'F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation.

Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressure > 800 psig.

Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

INSERT 3 during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, INSERT 4 Additionally, even with required minimum reactor coolant temperatures < 212°F, RCS temperatures may drift above 2121F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

INSERT 5

,or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, JAFNPP