ML070370526

Issuance of Amendment Technical Specification 4.1.1 Regarding Control Rod System Surveillance Requirements

ML070370526
Person / Time
Site:	Nine Mile Point
Issue date:	03/15/2007
From:	Pickett D NRC/NRR/ADRO/DORL/LPLA
To:	O'Connor T Nine Mile Point
Pickett D, NRR/DORL, 415-1364
References
TAC MD3360
Download: ML070370526 (13)

Text

March 15, 2007 Mr. Timothy J. OConnor Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P. O. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATION 4.1.1 REGARDING CONTROL ROD SYSTEM SURVEILLANCE REQUIREMENTS (TAC NO.

MD3360)

Dear Mr. OConnor:

The Commission has issued the enclosed Amendment No. 193 to Facility Operating License No. DPR-63 for the Nine Mile Point Nuclear Station, Unit No. 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated October 19, 2006, as supplemented by letter dated January 5, 2007.

The amendment revises the Surveillance Requirement (SR) in TS 4.1.1.c, Scram Insertion Times, to modify the conditions under which scram time testing (STT) of control rods is required, and to add a requirement to perform STT on a defined portion of control rods, at a specified frequency, during the operating cycle. The amendment also revises the SR in TS 4.1.7.c, "Minimum Critical Power Ratio (MCPR)," to add a requirement to determine the MCPR operating limits following completion of control rod STT pursuant to TS 4.1.1.c.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220

Enclosures:

1. Amendment No. 193 to DPR-63

2. Safety Evaluation cc w/encls: See next page

March 15, 2007 Mr. Timothy J. OConnor Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATION 4.1.1 REGARDING CONTROL ROD SYSTEM SURVEILLANCE REQUIREMENTS (TAC NO.

MD3360)

Dear Mr. OConnor:

The Commission has issued the enclosed Amendment No. 193 to Facility Operating License No. DPR-63 for the Nine Mile Point Nuclear Station, Unit No. 1 (NMP-1). The amendment consists of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated October 19, 2006, as supplemented by letter dated January 5, 2007.

The amendment revises the Surveillance Requirement (SR) in TS 4.1.1.c, Scram Insertion Times, to modify the conditions under which scram time testing (STT) of control rods is required, and to add a requirement to perform STT on a defined portion of control rods, at a specified frequency, during the operating cycle. The amendment also revises the SR in TS 4.1.7.c, "Minimum Critical Power Ratio (MCPR)," to add a requirement to determine the MCPR operating limits following completion of control rod STT pursuant to TS 4.1.1.c.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220

Enclosures:

1. Amendment No. 193 to DPR-63

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC RidsNrrLASLittle RidsNrrdirsItsb RidsNrrAcrsAcnwMailCenter LPLI-1 RidsNrrPMDPickett RidsNrrDssSbwb RidsRgn1MailCenter MDavid RidsOGCRp JBudzynski GHill (2)

Package No.: ML070740458 Amendment No.: ML070370526 Tech Spec No.: ML OFFICE LPLI-1/PE LPLI-1/PM LPLI-1/LA SBWB/BC ITSB/BC OGC LPLI-1/BC(A)

NAME MDavid DPickett SLittle GCranston as TKobetz MBarkman JBoska signed DATE 2/28/ 07 2/27/ 07 2/27/ 07 01/19 / 07 3/02/ 07 3/12/ 07 3/14/ 07 OFFICIAL RECORD COPY

Nine Mile Point Nuclear Station, Unit No. 1 cc:

Mr. Michael J. Wallace Mark J. Wetterhahn, Esquire President Winston & Strawn Nine Mile Point Nuclear Station, LLC 1700 K Street, NW c/o Constellation Energy Group Washington, DC 20006 750 East Pratt Street Baltimore, MD 21202 Supervisor Town of Scriba Mr. Mike Heffley Route 8, Box 382 Senior Vice President and Chief Oswego, NY 13126 Nuclear Officer Constellation Generation Group Carey W. Fleming, Esquire 1997 Annapolis Exchange Parkway Senior Counsel Suite 500 Constellation Generation Group, LLC Annapolis, MD 21401 750 East Pratt Street, 17th Floor Baltimore, MD 21202 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 126 Lycoming, NY 13093 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Paul D. Eddy Electric Division NYS Department of Public Service Agency Building 3 Empire State Plaza Albany, NY 12223 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399

NINE MILE POINT NUCLEAR STATION, LLC (NMPNS)

DOCKET NO. 50-220 NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 193 License No. DPR-63

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nine Mile Point Nuclear Station, LLC (the licensee) dated October 19, 2006, as supplemented by letter dated January 5, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-63 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, which is attached hereto, as revised through Amendment No.193, is hereby incorporated into this license.

Nine Mile Point Nuclear Station, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented prior to completion of the spring 2007 refueling outage.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

John Boska, Acting Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: March 15, 2007

ATTACHMENT TO LICENSE AMENDMENT NO.193 TO FACILITY OPERATING LICENSE NO. DPR-63 DOCKET NO. 50-220 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 33 33 34 34 66 66

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 193 TO FACILITY OPERATING LICENSE NO. DPR-63 NINE MILE POINT NUCLEAR STATION, LLC (NMPNS)

NINE MILE POINT NUCLEAR STATION UNIT NO. 1 DOCKET NO. 50-220

1.0 INTRODUCTION

By letter dated October 19, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML063040602), as supplemented by letter dated January 5, 2007 (ADAMS Accession No. ML070220018), Nine Mile Point Nuclear Station, LLC (NMPNS, the licensee) submitted a request for an amendment to the Technical Specifications (TSs) for the Nine Mile Point Nuclear Station, Unit 1 (NMP1). The proposed amendment would revise the TS Surveillance Requirements (SRs) associated with TS 4.1.1.c, Scram Insertion Times, for control rod scram time testing (STT). STT is performed to periodically demonstrate that the control rods remain capable of being automatically inserted into the reactor vessel within the limits prescribed by the plant safety analysis. Specifically, STT of non-maintenance affected control rods would be allowed during power operations prior to exceeding 40% power, and the requirements to test "eight selected rods" after a reactor scram from rated pressure or any outage not initiated by a reactor scram would be eliminated. The proposed amendment would add a new SR to TS 4.1.1.c. This SR would require STT for "At least 20 control rods, on a rotating basis, on a frequency of less than or equal to once per 180 days of cumulative power operation, with reactor pressure above 800 psig." The proposed amendment would also revise TS 4.1.7.c, Minimum Critical Power Ratio (MCPR), to add a SR requiring that the MCPR operating limit be determined within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of completing scram time testing as required in TS 4.1.1.c.

The supplemental letter dated January 5, 2007, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on December 5, 2006 (71 FR 70562).

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, General Design Criteria (GDC) 10, Reactor design, requires that the reactor core and associated coolant, control, and protection systems be designed with appropriate margin to assure that specified acceptable fuel design limits (SAFDLs) are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences (AOOs).

GDC 26, Reactivity control system redundancy and capability, requires that control rods be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including AOOs such as stuck rods, SAFDLs are not exceeded.

GDC 29, Protection against anticipated operational occurrences, requires that the protection and reactivity control systems be designed to assure an extremely high probability of accomplishing their safety functions in the event of AOOs. The control rod drive (CRD) system scram function is intended to reliably control reactivity changes with an extremely high degree of probability during abnormal operational transients to ensure that SAFDLs are not exceeded.

The design-basis accident (DBA) and transient analyses assume that all of the control rods scram within prescribed limits. The resulting negative scram reactivity forms the basis for determination of plant thermal limits (for example, Minimum Critical Power Ratio - MCPR).

Surveillance of each individual control rod scram time ensures the scram reactivity assumed in the DBA and transient analyses can be met. Control rod scram time surveillance tests satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii), and are, therefore, required to be included in the NMP1 TSs.

3.0 TECHNICAL EVALUATION

The proposed SR revisions would improve the NMP1 STT requirements to be more consistent with those of other boiling-water reactors (BWRs) by means of: (1) allowing STT of non-maintenance affected control rods during power operation, prior to reaching 40% power, (2) collection of periodic STT data necessary to apply actual scram times for implementation of improved Option B MCPR operating limits, and (3) replacement of the redundant requirement to test eight selected rods after a reactor scram or other outage with a new requirement to periodically test at least 20 control rods on a rotating basis every 180 days.

These changes are, in general, consistent with the guidelines of NUREG-1433, "Standard Technical Specifications for General Electric Plants (BWR/4)," Revision 3. Certain deviations from the Standard TSs (STS) are necessary due to the non-standard content and format of the current custom TSs for NMP1.

The licensee will revise the TS Bases consistent with the proposed changes to the TSs. The TS Bases changes were provided for information only and do not require NRC approval.

3.1 TS Section 4.1.1.c, Scram Insertion Times The current NMP1 TSs require STT to be performed on all control rods after each refueling outage and prior to operation with reactor pressure above 800 pounds per square inch gauge (psig). In addition, the current NMP1 TSs require STT of eight selected control rods following a reactor scram or any outage not initiated by a reactor scram. The current NMP1 TSs do not require STT following maintenance on or modification to the control rod or CRD system which could affect the scram time of a control rod.

The licensee has proposed replacing the existing SRs for TS 4.1.1.c. The following discussion itemizes the existing SR and the new SR as proposed by the licensee.

Existing TS 4.1.1.c:

(1) After each major refueling outage and prior to power operation with reactor pressure above 800 psig, all operable control rods shall be scram time tested from the fully withdrawn position.

(2) Following each reactor scram from rated pressure, the mean 90% insertion time shall be determined for eight selected rods. If the mean 90% insertion time of the selected control rod drives does not fall within the range of 2.4 to 3.1 seconds or the measured scram time of any one drive for 90% insertion does not fall within the range of 1.9 to 3.6 seconds, an evaluation shall be made to provide reasonable assurance that proper control rod drive performance is maintained.

(3) Following any outage not initiated by a reactor scram, eight rods shall be scram tested with reactor pressure above 800 psig. The same criteria of 4.1.1.c(2) shall apply.

Proposed TS 4.1.1.c:

The maximum scram insertion time shall be demonstrated through measurement for*

(1) All control rods prior to thermal power exceeding 40% power with reactor pressure above 800 psig, after each major refueling outage or after a reactor shutdown that is greater than 120 days.

(2) Specifically affected individual control rods following maintenance on or modification to the control rod or control rod drive system which could affect the scram insertion time of those specific control rods with reactor pressure above 800 psig.

(3) At least 20 control rods, on a rotating basis, on a frequency of less than or equal to once per 180 days of cumulative power operation, with reactor pressure above 800 psig.

• For single control rod scram time tests, the control rod drive pumps shall be isolated from the accumulators.

The existing TSs require that STT be performed on all control rods prior to power operation following a refueling outage. The industry standard in NUREG-1433 is to perform STT on all control rods prior to exceeding 40% thermal power following core alterations or after a reactor shutdown that exceeds 120 days. The proposed SRs will permit STT for non-maintenance affected control rods to be performed with the reactor at power. This change will improve operational flexibility and reduce critical path outage activities. A new SR would require STT for those control rods that experienced maintenance or modifications that could affect the scram insertion time.

The existing TSs do not provide for periodic STT of the control rods. The only requirement for STT following a refueling outage is to test eight selected rods following a reactor scram or plant

shutdown. Operational experience has demonstrated that facilities can operate for an entire fuel cycle without a scram or plant shutdown. Thus, the capability of the control rods to insert within the assumed licensing basis would not necessarily be demonstrated by the existing TSs.

A new SR would include a requirement to perform STT on a defined portion of control rods, at a specified frequency during the operating cycle. Currently, many BWR licensees perform this proposed STT surveillance every 120 to 200 days, testing 10% of the total control rod population each time. This results in a yearly average of approximately 19 to 30% of the total control rod population being tested. The licensees proposed new SR would require STT on a frequency of less than or equal to once per 180 days of cumulative power operation, for at least 20 control rods, on a rotating basis, with reactor coolant pressure greater than 800 psig. The combination of the proposed surveillance frequency (180 days) and the number of control rods tested (20 out of a total of 129 rods equal to 15.5%) leads to approximately 31% of the total control rod population being tested each year of operation.

In order to evaluate the licensees request to scram time test at least 20 control rods every 180 days, the NRC staff requested historical plant-specific information regarding scram time test data in terms of relevant test results for multiple operating cycles. The licensee reported that between March 1995 and August 2005, approximately 1,200 individual control rod scram time tests had been performed. As a result of these 1,200 scram time tests, the licensee reported that 20 tests were not within one or more of the TS-required maximum scram insertion time limits (i.e., slow). However, the licensee also reported that the 90% scram insertion time limit of 5.3 seconds was met for all 20 tests. The licensee has taken appropriate action to correct deficiencies attributable to previous slow test results and does not consider the STT failures to be representative of current control rod system performance. Based on the previous test results and the licensees corrective actions, the staff concludes that testing at least 20 control rods every 180 days is sufficient to demonstrate that the control rod system is reliable.

The proposed surveillance frequency and the test population for the new TS 4.1.1.c was based on a review of current industry standard practice, with consideration of the current NMP1 operational practices and other SRs. The NRC staff concludes that the proposed SRs for TS 4.1.1.c represent an improvement over the existing SRs. Specifically, the staff believes that it is important to include a requirement to test all control rods following maintenance or modifications that could affect the scram insertion times. In addition, the staff believes that it is important to periodically perform STT to demonstrate that the control rods remain capable of performing their design functions. The new SRs include requirements for both of these items.

Therefore, considering that the proposed changes represent improvements to the existing TSs and that they are overall consistent with the industry standard as defined in NUREG-1433, the staff finds the above changes acceptable.

3.2 TS Section 4.1.7.c, Minimum Critical Power Ratio (MCPR)

The MCPR is the ratio of the fuel assembly power that would result in the onset of boiling transition (the critical power) to the actual fuel assembly power. The critical power at which boiling transition is calculated to occur has been adopted as a fuel design criterion. The MCPR Safety Limit is set such that 99.9% of the fuel rods avoid boiling transition when operation within the limit is maintained. The MCPR operating limit is established to ensure that no fuel damage results during AOOs. The MCPR operating limit provides protection against violating the fuel

cladding safety limit during the limiting power transients analyzed in Section XV of the NMP1 Updated Final Safety Analysis Report. The operating limit MCPR values are specified in the Core Operating Limits Report (COLR). TS 3.1.7.c and TS 4.1.7.c require that all MCPR values be greater than or equal to the operating limit MCPR values specified in the COLR when the reactor thermal power is greater than or equal to 25% of the rated thermal power.

The proposed amendment would add a SR to determine the MCPR operating limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following completion of the control rod STT per SR 4.1.1.c. The proposed SR is intended to demonstrate that the proper MCPR operating limit is used, based on the results of scram time testing, so that the MCPR safety limit will not be exceeded. This ensures that all analyzed transient results remain well within the design values for structures, systems, and components.

The methodology for use of the Option A and Option B MCPR limits is included in the NRC approved General Electric Standard Application for Reactor Fuel, GESTAR-II (Topical Report NEDE-24011-P-A, General Electric Standard Application for Reactor Fuel, GESTAR-II, latest approved version as specified in the COLR), which is currently referenced in the NMP1 TS Bases 3.1.7 and 4.1.7.

Currently, TS 3.1.1.c, Scram Insertion Times, minimum scram time speed is used to determine the operating limit MCPR values, using the Option A MCPR methodology from GESTAR-II. The Option B MCPR methodology approved in the same reference allows use of a faster mean control rod scram speed performance from a measured scram speed distribution to provide for a lower operating limit MCPR. In order to implement the Option B methodology, it must be demonstrated that the measured scram speed distribution is consistent with that used in the transient analyses. This requires additional scram speed data beyond what is currently required to comply with the TS scram speed limit. The proposed new SR in TS 4.1.1.c is used to determine the actual speed distribution. The operating limit MCPR values can then be determined based either upon the TS 3.1.1.c required scram times, or upon the mean value of the actual measured scram time distribution. Since the actual scram speed distribution may change after control rod maintenance or a startup, or even during an operating cycle, the Option B operating limit MCPR value must be re-determined within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after completion of each set of STT required by TS 4.1.1.c. The licensees proposed SR for TS 4.1.7c is based on the STS and is consistent with the specified completion time stated therein.

The NRC staff finds the proposed TS 4.1.7.c SR acceptable since it is consistent with the intent of the STS and is sufficient to generate the scram time data required to use the approved GESTAR-II Option B MCPR methodology.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration (71 FR 70562), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: John T. Budzynski Date: March 15, 2007