JAFP-08-0011, License Amendment Request Application for Technical Specification Changes Using the Consolidated Line- Item Improvement Process (CLIIP)

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

ML080510730
Person / Time
Site:	FitzPatrick
Issue date:	02/07/2008
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-08-0011
Download: ML080510730 (27)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP En ntlry P.O. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 Pete Dietrich Site Vice President - JAF February 7, 2008 JAFP-08-001' 1 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 License Amendment Request Application, for Technical, Specification Changes Using the Consolidated Line- Item Improvement Process, (CLIIP)

REFERENCE:

Federal R,egister.Notice 72 FR 63935, published'November 13,2007

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90 Entergy is submitting a request for an amendment to the technical specifications (TS) for the JamesA. FitzPatrick Nuclear Power Plant (JAFNPP). The proposed amendment would: (1) revise the TS surveillance requirement (SR)I frequency in TS 3.1.3, "Control Rod OPERABILITY", and (2)-revise Example 1.4-3 in[Section 1.4 "Frequency.' to clarify the applicability of the 1.25 surveillance test interval extension. The:

proposed change eliminates approximately 6,000 control rod manipulations per year. and, thereby, reduces unnecessary burden on, operators and enhances nuclear safety by reducing the opportunity for reactivity control events:

During the JAFNPP conversion to Improved Standard Technical Specifications, TS Section 3.3.1.2, required Action E.2, "Source Range. Monitoring Instrumentation" and associated bases were clarified to state fully insert all insertable control rods for the limiting condition for operation (LCO). provides a description and evaluation of the proposed TS changes. provides-the proposed-changes to. the current TS on marked-up pages. provides the proposed- TS changes in final typed-format. 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 pageswill be submitte& with a future update in accordance with TS 5.5.11, "Technical Specifications (TS).

Bases Control Program". provides a list of commitments made as part of this submittal. f

JAFP-08-0011 Page 2 of 3 Entergy requests approval of the proposed License Amendment by May 8, 2008, with the amendment being implemented within 30 days.

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.

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.

tExecuted on the. 7.ýh day -o~fFebruary,-2008.

Pete Dieffich Site Vice President PD/ed

-Attachments: 1. Description And evaluation of the proposed TS changes 2., Proposed changes to the current TS on marked up pages 3.. Proposed TS changes in final typed format.

4. Proposed changes to the!current TS Bases on marked up pages

5. List of Commitments

-cc: next page

JAFP-08-0011 Page 3 of 3 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 Plant Licensing Branch I-1 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, 1 0 th Floor Albany, NY 12223 Mr. Paul Tonko, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399

JAFP-08-0011 Attachment 1 Description and Evaluation Application"for Amendment to Technical Specifications Regarding Revision of Control Rod Notch Surveillance Frequency, Clarify SRMI Insert Control Rod Action, and Clarify Frequency Consistent with TSTF-475 Revision 1

JAFP-08-0011 Attachment 1 1.0 Description The proposed amendment would: (1) revise the Technical Specification (TS) surveillance requirement (SR 3.1.3.2) frequency in TS 3.1.3,"'Control Rod OPERABILITY", and (2) revise Example 1.4-3 in Section 1.4 "Frequency" to clarify the applicability of the 1.25 surveillance test interval extension.

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 the James A. FitzPatrick Nuclear Power Plant (JAFNPP) and justify this amendment for the incorporation of the changes to the JAFNPP TS.

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.

During the JAFNPP conversion to Improved Standard Technical Specifications, TS Section 3.3.1.2, required Action E.2, "Source Range Monitoring Instrumentation" and associated bases were clarified to state fully insert all insertable control rods for the limiting condition for operation (LCO), therefore we are not requesting a change to this section of the Technical Specifications.

Page 1 of 2

JAFP-08-0011 Attachment 1 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination 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 JAF 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 JAF, and commits to establishing TS Bases as proposed in TSTF-475, Revision 1. Attachment 4 provides a copy of the JAF TS Bases marked-up to show the changes required by TSTF-475 Revision 1.

These changes are based on TSTF change traveler TSTF-475 Revision 1 that proposes revisions to the Standard Technical Specifications (STS) by: (1) revising the frequency of SR 3.1.3.2, notch testing of fully withdrawn control rod, from "7 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of RWM" to "31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM", and (2) 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.

Entergy is only proposing to adopt changes 1 and 3 for JAF, as discussed previously change 2 was adopted during the conversion to STS, the appropriate TS and bases pages are included in attachments 2 and 4 respectively, for reference.

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 JAF and the evaluation is hereby incorporated by reference for this application.

Page 2 of 2

JAFP-08-0011 Attachment 2 Proposed Technical Specification Changes (Mark up)

Pages 1.4-5 3.1.3-2 3.1.3-4 3.1.3-5 3.1.4-3 3.3.1.2-2 (No change on this page, reference only)

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

-- - - - - ------ NOTE- ------------

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

_ 25% RTP.

Perform channel adjustment. 7 days The interval continues whether or not the plant operation is < 25% RTP between performances.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% 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 _ 25% RTP to perform the Surveillance. The Surveillance is still considered to be within the "specified Frequency."

Therefore, if the Surveillance were not performed within the 7 day interval (plus the extension allowed by SR 3.0.2), but operation was < 25% 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 operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (plus the extension allowed by SR 3.0.2) with power _>25% RTP.

Once the plant reaches 25% 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 (plus the extension allowed by SR 3.0.2), there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

(continued)

JAFNPP 1.4-5 Amendment 27-4

Control Rod Operability 3.1.3 ACTIONS ,

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Perform SR 3.1.3.2 aPA- 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from SRR4 &n7 for each discovery of Condition withdrawn OPERABLE A concurrent with control rod. THERMAL POWER greater than the low power setpoint (LPSP) of the RWM AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A.4 Perform SR 3.1.1.1.

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 RWM may be bypassed other than Condition A or B. as allowed by LCO 3.3.2.1, 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.

AND C.2 Disarm the associated CRD. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)

JAFNPP 3.1.3-2 Amendment 27-4

Control Rod OPERABILITY 3.1.3 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 /> 8R 3.1.3.2 NOTE Not'cquircd to d unti 7 da control rod fis;Afit-hdraon. and THERMAL POWER i grcatcr than the L:PSP of the RWM.

'nst each full ... thdr+wn control..rod a.t le7 days fneteh.

SR 3.1.3.3 2 --------------- NOTE---------------- I Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each pa.iall, withdrawn control rod at least one 31 days J notch.

SR 3.1.3.4 3 Verify each control rod scram time from fully In accordance with I withdrawn to notch position 04 is < 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (continued)

JAFNPP 3.1.3-4 Amendment 2-74

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.3.6-4 Verify each control rod does not go to the withdrawn Each time the I overtravel position. control rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling (On the clean revised pages this surveillance will move to Page 3.1.3-4 and this page will be deleted.)

JAFNPP 3.1'.3-5 Amendment 2-74

Control Rod Scram Times 3.1.4 Table 3.1.4-1 (page I of 1)

Control Rod Scram Times

---

- - - - - ---------- NOTES--------------------------

1. OPERABLE control rods with scram times not within the limits of this Table are considered "slow."

2. Enter applicable Conditions and Required Actions of LCO 3.1.3, "Control Rod OPERABILITY,"

for control rods with scram times > 7 seconds to notch position 04. These control rods are inoperable, in accordance with SR 3.1.3.4=3, and are not considered "slow." I SCRAM TIMES (a) (b) when REACTOR STEAM DOME NOTCH POSITION PRESSURE >800 psig (seconds) 46 0.44 36 1.08 26 1.83 06 3.35 (a). Maximum scram time from fully withdrawn position, based on de-energization of scram pilot valve solenoids at time zero.

(b). Scram times as a function of reactor steam dome pressure, when

< 800 psig, are within established limits.

JAFNPP 3.1.4-3 Amendment 27-4

SRM Instrumentation 3.3.1.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more required SRMs D.1 Fully insert all insertable 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable in MODE 3 or 4. control rods.

AND D.2 Place reactor mode switch in the shutdown 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> position.

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

AND E.2 Initiate action to fully insert all insertable Immediately control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS

---

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

Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable MODE or other specified condition.

SURVEILLANCE FREQUENCY SR 3.3.1.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)

(No change required, page provided for reference only)

JAFNPP 3.3.1-.2-2 Amendment 274

JAFP-08-0011 Attachment 3 Proposed Technical Specification Changes (Final Typed)

Pages 1.4-5 3.1.3-2 3.1.3-4 3.1.4-3

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

-- - - - - - ----- NOTE-------------

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

> 25% RTP.

Perform channel adjustment. 7 days The interval continues whether or not the plant operation is < 25% RTP between performances.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% 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 > 25% RTP to perform the Surveillance. The Surveillance is still considered to be within the "specified Frequency."

Therefore, if the Surveillance were not performed within the 7 day interval (plus the extension allowed by SR 3.0.2), but operation was < 25% 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 operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (plus the extension allowed by SR 3.0.2) with power > 25% RTP.

Once the plant reaches 25% 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 (plus the extension allowed by SR 3.0.2), there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

(continued)

JAFNPP 1.4-5 Amendment

Control Rod Operability 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Perform SR 3.1.3.2 for each withdrawn 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of Condition I OPERABLE control rod. A concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A.4 Perform SR 3.1.1.1.

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 RWM may be bypassed other than Condition A or B. as allowed by LCO 3.3.2.1, 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.

AND C.2 Disarm the associated CRD. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)

JAFNPP 3.1.3-2 Amendment

Control Rod OPERABILITY 3.1.3 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 -------------- NOTE----------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least one notch. 31 days SR 3.1.3.3 Verify each control rod scram time from fully In accordance with withdrawn to notch position 04 is < 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 SR 3.1.3.4 Verify each control rod does not go to the withdrawn Each time the I overtravel position. control rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling JAFNPP 3.1.3-4 Amendment

Control Rod Scram Times 3.1.4 Table 3.1.4-1 (page 1 of 1)

Control Rod Scram Times

---

- ------ - - - - --------- NOTES--------------------------

1. OPERABLE control rods with scram times not within the limits of this Table are considered "slow."

2. Enter applicable Conditions and Required Actions of LCO 3.1.3, "Control Rod OPERABILITY,"

for control rods with scram times > 7 seconds to notch position 04. These control rods are inoperable, in accordance with SR 3.1.3.3, and are not considered "slow." I SCRAM TIMES (a) (b) when REACTOR STEAM DOME NOTCH POSITION PRESSURE > 800 psig (seconds) 46 0.44 36 1.08 26 1.83 06 3.35 (a). Maximum scram time from fully withdrawn position, based on de-energization of scram pilot valve solenoids at time zero.

(b). Scram times as a function of reactor steam dome pressure, when

< 800 psig, are within established limits.

JAFNPP 3.1.4-3 Amendment

JAFP-08-0011 Attachment 4 Proposed Technical Specification Bases Changes (Mark Up)

(Information Only)

Pages B 3.1.3-4 B 3.1.3-7 B 3.1.3-8 B 3.1.3-9 B 3.1.4-2 B 3.3.1.2-4 (No change on this page, reference only)

Control Rod OPERABILITY B 3.1.3 BASES ACTIONS A.1. A.2. A.3. and A.4 (continued) associated control rod drive must be disarmed (hydraulically) in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The allowed Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is acceptable, considering the reactor can still be shut down, assuming no additional control rods fail to insert, and provides a reasonable time to perform the Required Action in an orderly manner. The control rod must be isolated from both scram and normal insert and withdraw pressure. Isolating the control rod in this manner prevents damage to the stuck CRD. In addition, the control rod should be isolated while maintaining cooling water to the CRD.

Demonstrating the insertion capability of each withdrawn control rod must also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of Condition A concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM. SR 3.1.3.2 and SR 3.1.3.3 requires periodic tests of the control rod insertion capability of withdrawn control rods. Testing each withdrawn control rod ensures that a generic problem does not exist. This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." The Required Action A.3 Completion Time only begins upon discovery of Condition A concurrent with THERMAL POWER greater than the actual LPSP of the RWM since the notch insertions may not be compatible with the requirements of rod pattern control (LCO 3.1.6) and the RWM (LCO 3.3.2.1). 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 /> from discovery of Condition A concurrent with THERMAL POWER greater than the LPSP of the RWM provides a reasonable time to test the control rods, considering the potential for a need to reduce power to perform the tests.

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 fail 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 assumed 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 (continued)

JAFNPP B 3.1.3-4 Revision 0

Control Rod OPERABILITY B 3.1.3 BASES (continued)

SURVEILLANCE SR 3.1.3.1 REQUIREMENTS The position of each control rod must be determined to ensure adequate information on control rod position is available to the operator for determining control rod OPERABILITY and controlling rod patterns. Control rod position may be determined by the use of OPERABLE position indicators, by moving control rods to a position with an OPERABLE indicator, or by the use of other appropriate methods (such as taking voltage measurements using the position indicator probe connectors and determining the position using the resultant readings). The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of this SR is based on operating experience related to expected changes in control rod position and the availability of control rod position indications in the control room.

SR 3.1.3.2 and SR 3.1.3.3 Control rod insertion capability is demonstrated by inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves. The control rod may then be returned to its original position. This ensures the control rod is not stuck and is free to insert on a scram signal. These Surveillances are not required when THERMAL POWER is less than or equal to the actual LPSP of the RWM, since the notch insertions may not be compatible with the requirements of the Banked Position Withdrawal Sequence (BPWS) (LCO 3.1.6) and the RWM (LCO 3.3.2.1). The 7 day Frcqucncy of SR 3.1.3.2 is bascd on operating excrnc rclatcd to the ohanges in GRID pcrformnancc and tthc cancs~ot pe*"frming notch tc+tingf*or fully withdraWn controI r"ds. Partially withdrawn control rods are tested at a 31 day Frequency, based on the potential power reduction required to allow the control rod movement and .. n.idi*n.g the larFg testing sample of SR 3.1.3.2" Furthermore, the 31 day Frequency takes into account operating experience related to changes in CRD performance. At any time, if a control rod is immovable, a determination of the control rods OPERABILITY must be made and appropriate action taken. These This SRs aSe is modified by g Notes that allows 7 ,dys* .d 31 days Fespeet..ely- after withdrawal of the control rod (aftcr fu ll withdrawal fe, SR.1...3**2) and increasing power to above the LPSP of the RWM, to perform the Surveillance. This acknowledges that the control rod must be first withdrawn and THERMAL POWER must increase to above the LPSP before performance of the Surveillance, and therefore the Notes avoid potential conflicts with SR 3.0.3 and SR 3.0.4.

(continued)

JAFNPP B 3.1.3-7 Revision -14

Control Rod OPERABILITY B 3.1.3 BASES (continued)

SURVEILLANCE SR 3.1.3.4=3 REQUIREMENTS (continued) Verifying that the scram time for each control rod to notch position 04 is <

7 seconds provides reasonable assurance that the control rod will insert when required during a DBA or transient, thereby completing its shutdown function. This SR is performed in conjunction with the control rod scram time testing of SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," and the functional testing of SDV vent and drain valves in LCO 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves," overlap this Surveillance to provide complete testing of the assumed safety function. The associated Frequencies are acceptable, considering the more frequent testing performed to demonstrate other aspects of control rod OPERABILITY and operating experience, which shows scram times do not significantly change over an operating cycle.

SR 3.1.3.&-4 Coupling verification is performed to ensure the control rod is connected to the CRD and will perform its intended function when necessary. The Surveillance requires verifying a control rod does not go to the withdrawn overtravel position. The overtravel position feature provides a positive check on the coupling integrity since only an uncoupled CRD can reach the overtravel position. The verification is required to be performed any time a control rod is withdrawn to the "full out" position (notch position 48) or prior to declaring the control rod OPERABLE after work on the control rod or CRD System that could affect coupling. This includes control rods inserted one notch and then returned to the "full out" position during the performance of SR 3.1.3.2. This Frequency is acceptable, considering the low probability that a control rod will become uncoupled when it is not being moved and operating experience related to uncoupling events.

Coupling verification is required to support the administrative controls of the improved BPWS control rod insertion process. When performing a shutdown of the plant, an optional BPWS control rod sequence (Ref. 6) may be used provided that all withdrawn control rods have been confirmed to be coupled. The rods may be inserted without the need to stop at intermediate positions since the possibility of a CRDA is eliminated by the confirmation that withdrawn control rods are coupled.

(continued)

JAFNPP B 3.1.3-8 Revision 8

Control Rod OPERABILITY B,3.1.3 BASES (continued)

REFERENCES 1. UFSAR, Section 16.6.

2. UFSAR, Section 14.6.

3. UFSAR, Section 14.5.

4. 10 CFR 50.36(c)(2)(ii).

5. NEDO-21231, Banked Position Withdrawal Sequence, Section 7.2, January 1977.

6. NEDO-33091-A, Revision 2, Improved BPWS Control Rod Insertion Process, July 2004.

Th JAFNPP B 3.1.3-9 Revision 8

Control Rod Scram Times B 3.1.4 BASES APPLICABLE RATE (APLHGR)"), which ensure that no fuel damage will occur SAFETY ANALYSES if these limits are not exceeded. Above 800 psig, the scram (continued) function is designed to insert negative reactivity at a rate fast enough to prevent the actual MCPR from becoming less than the MCPR SL, during the analyzed limiting power transient. Below 800 psig, the scram function is assumed to mitigate the control rod drop accident (Ref. 4) and, therefore, also provides protection against violating fuel damage limits during reactivity insertion accidents (see Bases for LCO 3.1.6, "Rod Pattern Control"). For the reactor vessel overpressure protection analysis, the scram function, along with the safety/relief valves, ensure that the peak vessel pressure is maintained within the applicable ASME Code limits.

Control rod scram times satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref.

5).

LCO The scram times specified in Table 3.1.4-1 are required to ensure that the scram reactivity assumed in the DBA and transient analysis is met (Ref. 6).

To account for single failures and "slow" scramming control rods, the scram times specified in Table 3.1.4-1 are faster than those assumed in the design basis analysis. The scram times have a margin that allows 10 control rods to have scram times exceeding the specified limits (i.e., "slow" control rods) assuming a single stuck control rod (as allowed by LCO 3.1.3, "Control Rod OPERABILITY") and an additional control rod failing to scram per the single failure criterion. The scram times are specified as a function of reactor steam dome pressure to account for the pressure dependence of the scram times. The scram times are specified relative to measurements based on reed switch positions, which provide the control rod position indication. The reed switch closes ("pickup") when the index tube passes a specific location and then opens ("dropout") as the index tube travels upward. Verification of the specified scram times in Table 3.1.4-1 is accomplished through measurement of the "dropout" times. To ensure that local scram reactivity rates are maintained within acceptable limits, no more than two of the allowed "slow" control rods may occupy adjacent locations.

Table 3.1.4-1 is modified by two Notes which state that control rods with scram times not within the limits of the table are considered "slow" and that control rods with scram times > 7 seconds are considered inoperable as required by SR 3.1.3.4=3. I (continued)

JAFNPP B 3.1.4-2 Revision 0

SRM Instrumentation B 3.3.1.2 BASES ACTIONS A.1 and B.1 (continued)

With three required SRMs inoperable, Required Action B.1 allows no positive changes in reactivity (control rod withdrawal must be immediately suspended) due to inability to monitor the changes. Required Action A.1 still applies and allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore monitoring capability prior to requiring control rod insertion. This allowance is based on the limited risk of an event during this time, provided that no control rod withdrawals are allowed, and 'the desire to concentrate efforts on repair, rather than to immediately shut down, with no SRMs OPERABLE.

C.1 In MODE 2, if the required number of SRMs is not restored to OPERABLE status within the allowed Completion Time, the reactor shall be placed in MODE 3. With all control rods fully inserted, the core is in its least reactive state with the most margin to criticality. The allowed Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 in an orderly manner and without challenging plant systems.

D.1 and D.2 With one or more required SRMs inoperable in MODE 3 or 4, the neutron flux monitoring capability is degraded or nonexistent. The requirement to fully insert all insertable control rods ensures that the reactor will be at its minimum reactivity level while no neutron monitoring capability is available.

Placing the reactor mode switch in the shutdown position prevents subsequent control rod withdrawal by maintaining a control rod block. The allowed Completion Time of I hour is sufficient to accomplish the Required Action, and takes into account the low probability of an event requiring the SRM occurring during this interval.

E.1 and E.2 With one or more required SRMs inoperable in MODE 5, the ability to detect local reactivity changes in the core during refueling is degraded or nonexistent. CORE ALTERATIONS must be immediately suspended and action must be immediately initiated to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

(continued)

(No change required, page provided for reference only)

JAFNPP B 3.3.1.2-4 Revision 0

JAFP-08-0011 Attachment 5 List of Commitments

JAFP-08-0011 Attachment 5 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 (Checkone) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Entergy will establish TS Bases for [TS B 3.1.3, and TS B X Within 30 days 3.1.4] consistent with those shown in TSTF-475, Revision 1, of amendment "Control Rod Notch Testing Frequency and SRM Insert issuance Control Rod Action."

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