RS-06-164, Request for Amendment to Technical Specifications to Revise Control Rod Scram Time Testing Frequency
| ML063170331 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/13/2006 |
| From: | O'Neill T AmerGen Energy Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-06-164 | |
| Download: ML063170331 (11) | |
Text
ArnerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 RS-06-164 November 13, 2006 www.exeloncorp.coni U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 erG An Fxelon Company
Subject:
Request for Amendment to Technical Specifications to Revise Control Rod Scram Time Testing Frequency 10 CFR 50.90 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," AmerGen Energy Company, LLC (AmerGen) requests an amendment to Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1. The proposed change revises Technical Specification (TS) 3.1.4, "Control Rod Scram Times." Specifically, this change modifies the frequency of Surveillance Requirement 3.1.4.2, control rod scram time testing, from "120 days cumulative operation in MODE 1" to "200 days cumulative operation in MODE 1."
This change is being submitted in accordance with Technical Specification Task Force (TSTF) traveler TSTF-460-A, "Control Rod Scram Time Testing Frequency," Revision 0. A notice announcing the availability of this proposed TS change using the consolidated line item improvement process (CLIIP) was published in the Federal Register on August 23, 2004 (69 FR 51864). In accordance with the NRC safety evaluation associated with this CLIIP, Attachment 4 of this letter contains a regulatory commitment to revise the associated TS Bases.
This request is subdivided as follows :
" Attachment 1 provides an evaluation supporting the proposed change.
" contains the marked up TS page with the proposed change indicated.
" contains the marked up TS Bases page with the change indicated. The TS Bases page is provided for information only.
" provides the regulatory commitment associated with this change.
AmerGen requests approval of the proposed amendment within one year of the date of this letter. Upon approval, the amendment will be implemented within 60 days. The requested approval date and implementation period will allow sufficient time to effectively plan and schedule the activities associated with scram time testing.
November 13, 2006 U. S. Nuclear Regulatory Commission Page 2 The proposed change has been reviewed by the Plant Operations Review Committee, and approved by the Nuclear Safety Review Board in accordance with the Quality Assurance Program.
We are notifying the State of Illinois of this application for a change to the TS by transmitting a copy of this letter and its attachments to the designated State Official.
H you have any questions concerning this letter, please contact Mr. David Gullott at (630) 657-2819.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 13th day of November 2006.
Respectfully, Thomas S. O'Neill Vice President -Regulatory and Legal Affairs Attachments:
1. Evaluation of Proposed Change
- 2. Marked Up Technical Specifications Page
- 3. Marked Up Technical Specifications Bases Page
- 4.
Summary of Regulatory Commitment
ATTACHMENT 1 Evaluation of Proposed Change Subject : Request for Amendment to Technical Specifications to Revise Control Rod Scram Time Testing Frequency 1.0 DESCRIPTION 2.0 PROPOSED CHANGE
3.0 BACKGROUND
4.0 TECHNICAL ANALYSIS
5.0 REGULATORY ANALYSIS
5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Crite 6.0 COMMITMENT
7.0 ENVIRONMENTAL CONSIDERATION
8.0 PRECEDENT
9.0 REFERENCES
1.0 DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," AmerGen Energy Company, LLC (AmerGen) requests an amendment to Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1. This change is being submitted in accordance with Technical Specification Task Force (TSTF) traveler TSTF-460-A, "Control Rod Scram Time Testing Frequency," Revision 0. A notice announcing the availability of this proposed TS change using the consolidated line item improvement process (CLIIP) was published in the Federal Register on August 23, 2004 (69 FR 51864).
2.0 PROPOSED CHANGE
The proposed change revises Technical Specification (TS) 3.1.4, "Control Rod Scram Times."
Specifically, this change modifies the frequency of Surveillance Requirement (SR) 3.1.4.2, control rod scram time testing, from "120 days cumulative operation in MODE 1" to "200 days cumulative operation in MODE V" provides a TS page markup indicating the proposed change.
3.0 BACKGROUND
ATTACHMENT 1 Evaluation of Proposed Change The background for this application is adequately addressed by the CLIIP Notice of Availability published on August 23, 2004 (69 FR 51864) and TSTF-460-A.
4.0 TECHNICAL ANALYSIS
AmerGen has reviewed the safety evaluation (SE) published on August 23, 2004 (69 FR 51864) as part of the CUIP Notice of Availability. This verification included a review of the NRC SE and the supporting information provided to support TSTF-460-A. AmerGen has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC are applicable to CPS and justify this amendment for the incorporation of the changes to the CPS TS.
As described in the CLI I P model SE, part of the justification for the change in surveillance frequency is the high reliability of the CPS control rod drive system. As requested in the Notice of Availability published on August 23, 2004 (69 FR 51864), the historical performance of the control rod drive (CRD) system at CPS is provided.
To assess the historical performance of the CRD system, the CRD scram time test results were reviewed for the last seven fuel cycles plus the current operating cycle; covering the period from May 1992 through August 2006. Over this period, there were 2180 valid individual CRD scram time data points identified, with 22 of these individual tests resulting in scram times slower than the TS scram insertion time limits.
The 1.01 % incidence of slow control rod scram times demonstrates the high reliability of the CPS CRD system. This high reliability and the more restrictive slow control rod acceptance criteria of 7.5%, support extension of the SR 3.1.4.2 surveillance frequency as described above.
5.0 REGULATORY ANALYSIS 5.1 No Significant Hazards Consideration 52 Applicable Regulatory Requirements/Criteria 6.0 COMMITMENT 8.0 PRECEDENT
9.0 REFERENCES
ATTACHMENT 1 Evaluation of Proposed Change AmerGen has reviewed the proposed no significant hazards consideration determination published on August 23, 2004 (69 FR 51864) as part of the CLIIP.
AmerGen has concluded that the proposed determination presented in the notice is applicable to CPS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (a).
The applicable regulatory requirements and guidance associated with this application are adequately addressed by the CLIIP Notice of Availability published on August 23, 2004 (69 FR 51864) and TSTF-460-A.
As discussed in the CLAP model SE published in the Federal Register on August 23, 2004 (69 FR 51864) for this TS improvement, AmerGen is making the following regulatory commitment with the understanding that the NRC will include it as a condition for the issuance of the requested amendment:
AmerGen will incorporate the revised acceptance criterion value of 7.5 percent into the CPS TS Bases for SR 3.1.4.2 in accordance with the Bases Control Program described in TS 5.5.11, "Technical Specifications (TS) Bases Control Program."
7.0 ENVIRONMENTAL CONSIDERATION
AmerGen has reviewed the environmental evaluation included in the model SE published on August 23, 2004 (69 FR 51864) as part of the CLIIP. AmerGen has concluded that the NRC's findings presented in that evaluation are applicable to CPS and the evaluation is hereby incorporated by reference for this application.
This application is being made in accordance with the CLAP. AmerGen is not proposing variations or deviations from the TS changes described in TSTF-460-A or the NRC's model SE published on August 23, 2004 (69 FR 51864).
Federal Register Notice : Notice of Availability of Model Application Concerning Technical Specifications Improvement Regarding Revision to the Control Rod Scram Time Testing Frequency in STS 3.1.4, "Control Rod Scram Times" for General Electric Boiling Water Reactors Using the Consolidated Line Item Improvement Process, published August 23, 2004 (69 FR 51864)
ATTACHMENT 2 Marked Up Technical Specifications Page
SURVEILLANCE REQUIREMENTS CLINTON 3.1-12 Control Rod Scram Times 3.1.4
NOTE -----------------------------------
During single control rod scram time Surveillances, the control rod drive (CRD) pumps shall be isolated from the associated scram accumulator.
(continued)
Amendment No.
SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify each control rod scram time is within Prior to the limits of Table 3.1.4-1 with reactor exceeding steam dome pressure Z! 950 psig.
40% RTP after fuel movement within the reactor pressure vessel AND Prior to exceeding 40t RTP after each reactor shutdown A 120 days SR 3.1.4.2 Verify, for a representative sample, each fd ays O~C tested control rod scram time is within the cumulative limits of Table 3.1.4-1 with reactor steam operation in dome pressure ? 950 psig.
MODE 1 SR 3.1.4.3 Verify each affected control rod scram time Prior to is within the limits of Table 3.1.4-1 with declaring any reactor steam dome pressure.
control rod OPERABLE after work on control rod or CRD System that could affect scram time
ATTACHMENT 3 Marked Up Technical Specifications Bases Page
BASES SURVEILLANCE SR 3.1.4.2 REQUIREMENTS Additional testing of a sample of control rods is required to verify the continued performance of the scram function during the cycle.
A representative sample contains at least 1OW of the control rods.
The samDle remains "representative" if no more than f the control rods in tested sample are determined to be "slow."
If more than of the sample is declared to be "slow" per the criteria 4-1, addition ntrol rods are tested until erion (i.e., 20' f the entire sample size 1-ed, or until the to a number of "slow" control out the core, from all surveillances) exceed the For planned testing, the control rods selected for le should be different for each test.
Data from dvertent scrams should be used whenever possible to avoid unnecessary testing at power, even if the cons with data were previously tested in a sample.
The~
ay Frequency is based on operating experience the as shown control rod scram times do not significantly change over an operating cycle.
This Frequency is also reasonable, based on the additional Surveillances done on the CRDs at more frequent intervals in accordance with LCO 3.1.3 and LCO 3.1.5, "Control Rod Scram Accumulators."
SR 3.1.4.3 CLINTON B 3.1-26 Control Rod Scram Times B 3. 1.4 With regard to scram time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 8)
When work that could affect the scram insertion time is performed on a control rod or the CRD System, testing must be done to demonstrate that each affected control rod retains adequate scram performance over the range of applicable reactor pressures from zero to the maximum issible pressure.
The scram testing must be performed once before declaring the control rod OPERABLE.
The required scram time testing must demonstrate that the affected control rod is still within acceptable limits by demonstrating an acceptable scram insertion time to notch position 13.
The scram time acceptance criteria for this alternate test shall be determined by linear interpolation between 0.95 seconds at a reactor coolant pressure of 0 prig and 1.40 seconds at 950 psig.
The limits for reactor pressures < 950 psig are established based on a high (continued)
Revision No.
ATTACHMENT 4 Summary of Regulatory Commitments Summary of Regulatory Commitments Commitment Commitment Date AmerGen will incorporate the revised acceptance criterion value of During implementation 7.5 percent into the CPS TS Bases for SR 3.1.4.2 in accordance of TS amendment with the Bases Control Program described in TS 5.5.11, "Technical Specifications (TS) Bases Control Program."