ML070530646
| ML070530646 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/26/2007 |
| From: | James Kim NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Kansler M Entergy Nuclear Operations |
| kim J, NRR/ADRO/DORL, 415-4125 | |
| References | |
| TAC MD4085 | |
| Download: ML070530646 (14) | |
Text
March 26, 2007 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:
ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) CHANGE TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES (TAC NO. MD4085)
Dear Mr. Kansler:
The Commission has issued the enclosed Amendment No. 226 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated December 27, 2006.
The proposed amendment would revise Limiting Condition for Operation (LCO) 3.14.A to adopt the TSTF-484, Revision 0, Use of Technical Specification 3.10.1 for Scram Time Testing Activities.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosures:
- 1. Amendment No. 226 to License No. DPR-35
- 2. Safety Evaluation cc w/encls: See next page
March 26, 2007 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:
ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) CHANGE TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES (TAC NO. MD4085)
Dear Mr. Kansler:
The Commission has issued the enclosed Amendment No. 226 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated December 27, 2006.
The proposed amendment would revise Limiting Condition for Operation (LCO) 3.14.A to adopt the TSTF-484, Revision 0, Use of Technical Specification 3.10.1 for Scram Time Testing Activities.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosures:
- 1. Amendment No. 226 to License No. DPR-35
- 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC RidsNrrDorlLpla RPowell, RI RidsOGC RP PDI-I R/F RidsNrrLASLittle RidsNrrPMJKim GHill (2)
RidsAcrsAcnwMail TWertz Accession Number: ML070530646 OFFICE LPL1-1/PM LPL1-1/LA ITSB/BC OGC LPL1-1/BC NAME JKim SLittle TKobetz SUttal DPickett DATE 3/1/07 3/1/07 3/1/07 3/19/07 3/23/07 OFFICIAL RECORD COPY
ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.
DOCKET NO. 50-293 PILGRIM NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 226 License No. DPR-35
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment filed by Entergy Nuclear Operations, Inc. (the licensee) dated December 27, 2006, 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 1; 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 3.B of Facility Operating License No. DPR-35 is hereby amended to read as follows:
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 226, are hereby incorporated into the license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of the date of issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Douglas V. Pickett, Chief (Acting)
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 26, 2007
ATTACHMENT TO LICENSE AMENDMENT NO. 226 FACILITY OPERATING LICENSE NO. DPR-35 DOCKET NO. 50-293 Replace the following page of the Facility Operating License with the attached revised page.
The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Remove Insert 3 3 Replace the following pages of the 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 Insert 3/4.14-1 3/4.14-1 3/4.14-2 3/4.14-2
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 226 TO FACILITY OPERATING LICENSE NO. DPR-35 ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.
PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
By letter dated December 27, 2006 (ADAMS Accession No. ML070040441), Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Pilgrim Nuclear Power Station (Pilgrim) Technical Specifications (TSs).
The proposed changes would revise Limiting Condition for Operation (LCO) 3.14.A, and the associated Bases, by expanding its scope to include provisions for temperature excursions greater than 212 oF as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. Pilgrim TS LCO 3.14.A is equivalent to the improved standard Technical Specification LCO 3.10.1.
These changes are based on TS Task Force (TSTF) change traveler TSTF-484, Revision 0 that has been approved generically for the boiling-water reactor (BWR) Standard TS, NUREG-1433 (BWR/4) and NUREG-1434 (BWR/6) by revising LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212 oF as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. A notice announcing the availability of this proposed TS change using the consolidated line item improvement process was published in the Federal Register on November 27, 2006 (71 FR 68642).
Since the required schedule for issuance of an amendment would not accommodate the normal biweekly publication of no significant hazard consideration (NSHC) notice, an individual notice was published in the Federal Register on February 20, 2007 (72 FR 7776).
2.0 REGULATORY EVALUATION
2.1 Inservice Leak and Hydrostatic Testing The reactor coolant system (RCS) serves as a pressure boundary and also serves to provide a flow path for the circulation of coolant past the fuel. In order to maintain RCS integrity,Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code
(ASME Code) requires periodic hydrostatic and leakage testing. Hydrostatic tests are required to be performed once every 10 years, and leakage tests are required to be performed each refueling outage. Appendix G to 10 CFR Part 50 states that pressure tests and leak tests of the reactor vessel that are required by Section XI of the ASME Code must be completed before the core is critical.
NUREG-1433, General Electric Plants, BWR/4, Revision 3, Standard Technical Specifications (STS) and NUREG-1434, General Electric Plants, BWR/6, Revision 3, STS both currently contain LCO 3.10.1, Inservice Leak and Hydrostatic Testing Operation. LCO 3.10.1 was created to allow for hydrostatic and leakage testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 oF, provided certain secondary containment LCOs are met.
TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities, modifies the Pilgrim LCO 3.14.A to allow the licensee to implement LCO 3.14.A, while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceed 212 oF during testing. This modification does not alter current requirements for hydrostatic and leakage testing as required by Appendix G to Title 10 of the Code of Federal Regulations (10 CFR) Part 50.
2.2 Control Rod Scram Time Testing Control rods function to control reactor power level and to provide adequate excess negative reactivity to shut down the reactor from any normal operating or accident condition at any time during core life. The control rods are scrammed by using hydraulic pressure exerted by the control rod drive (CRD) system. General Design Criterion (GDC) 10 of Appendix A to 10 CFR Part 50 states that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. The scram reactivity used in design-basis accidents (DBA) and transient analyses is based on an assumed control rod scram time.
NUREG-1433, General Electric Plants, BWR/4, Revision 3, STS and NUREG-1434, General Electric Plants, BWR/6, Revision 3, STS both currently contain surveillance requirements (SRs) to conduct scram time testing when certain conditions are met in order to ensure that GDC 10 is satisfied. SR 3.1.4.1 requires scram time testing to be conducted following a shutdown greater than 120 days, while SR 3.1.4.4 requires scram time testing to be conducted following work on the CRD system or following fuel movement within the affected core cell. Both SRs must be performed at reactor steam dome pressure greater than or equal to 950 psig and prior to exceeding 40 percent rated thermal power (RTP). SR 3.1.4.1 and SR 3.1.4.4 of STS correspond to the Pilgrim SR 4.3.C.1.
TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities, would modify Pilgrim LCO 3.14.A to allow SR 4.3.C.1 to be conducted in Mode 4 with average reactor coolant temperature greater than 212 oF. Scram time testing would be performed in accordance with LCO 3.3.C, Scram Insertion Times. This modification to LCO 3.14.A does not alter the means of compliance with GDC 10.
3.0 TECHNICAL EVALUATION
The existing provisions of LCO 3.14.A at Pilgrim allow for hydrostatic and leakage testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 oF, while imposing Mode 3 secondary containment requirements. Under the existing provision, LCO 3.14.A would have to be implemented prior to hydrostatic and leakage testing. As a result, if LCO 3.14.A was not implemented prior to hydrostatic and leakage testing, hydrostatic and leakage testing would have to be terminated if average reactor coolant temperature exceeded 212 oF during the testing. TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities, modifies Pilgrim LCO 3.14.A to allow the licensee to implement LCO 3.14.A, while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceed 212 oF during testing. As discussed in the TSTF Safety Evaluation (SE),
the modification will allow completion of testing without the potential for interrupting the test in order to reduce reactor vessel pressure, cool the RCS, and restart the test below 212 oF. Since the current LCO 3.14.A allows testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 oF, the proposed change does not introduce any new operational conditions beyond those currently allowed.
The current SR 4.3.C.1 for Pilgrim requires that control rod scram time be tested at reactor steam dome pressure greater than or equal to 950 psig and before exceeding 40 percent RTP.
Performance of control rod scram time testing is typically scheduled concurrent with inservice leak or hydrostatic testing while the RCS is pressurized. Because of the number of control rods that must be tested, it is possible for the inservice leak or hydrostatic test to be completed prior to completing the scram time test. Under existing provisions, if scram time testing cannot be completed during the LCO 3.14.A inservice leak or hydrostatic test, scram time testing must be suspended. Additionally, if LCO 3.14.A is not implemented and average reactor coolant temperature exceeds 212 oF while performing the scram time test, scram time testing must also be suspended. In both situations, scram time testing is resumed during startup and is completed prior to exceeding 40 percent RTP. TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities, modifies Pilgrim LCO 3.14.A to allow the licensee to complete scram time testing initiated during inservice leak or hydrostatic testing. As stated earlier (and as discussed in the TSTF SE), since the current LCO 3.14.A allows testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 oF, the proposed change does not introduce any new operational conditions beyond those currently allowed.
Completion of scram time testing prior to reactor criticality and power operations results in a more conservative operating philosophy with attendant potential safety benefits.
It is acceptable to perform other testing concurrent with the inservice leak or hydrostatic test provided that this testing can be performed safely and does not interfere with the leak or hydrostatic test. However, it is not permissible to remain in TS 3.14.A solely to complete such testing following the completion of inservice leak or hydrostatic testing and scram time testing.
Since the tests are performed with the reactor pressure vessel (RPV) nearly water solid, at low decay heat values, and near Mode 4 conditions, the stored energy in the reactor core will be very low. Small leaks from the RCS would be detected by inspections before a significant loss of inventory would occur. In addition, two low-pressure emergency core cooling systems (ECCS) injection/spray subsystems are required to be operable in Mode 4 by TS 3.5.A.5, Core and Containment Cooling Systems. In the event of a large RCS leak, the RPV would rapidly
depressurize and allow operation of the low pressure ECCS. The capability of the low pressure ECCS would be adequate to maintain the fuel covered under the low decay heat conditions during these tests. Also, LCO 3.14.A requires that secondary containment and standby gas treatment system be operable and capable of handling any airborne radioactivity or steam leaks that may occur during performance of testing.
The protection provided by the normally required Mode 4 applicable LCOs, in addition to the secondary containment requirements required to be met by LCO 3.14.A, minimizes potential consequences in the event of any postulated abnormal event during testing. In addition, the requested modification to LCO 3.14.A does not create any new modes of operation or operating conditions that are not currently allowed. The NRC staff has determined that no factors specific to Pilgrim change the applicability of the TSTF SE analysis with respect to the proposed changes. Therefore, the NRC staff finds the proposed change to be acceptable.
4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of facility, in accordance with the amendment, would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
The NRC staff reviewed the NSHC evaluation provided by the licensee in its application. The NRC staff has made a final determination that NSHC consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91. The NRC staffs final determination is presented below:
Criterion 1The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
Technical Specifications currently allow for operation at greater than 212EF while imposing MODE 4 requirements in addition to the secondary containment requirements required to be met. The protection provided by the normally required Mode 4 applicable LCOs, in addition to the secondary containment requirements required to be met by LCO 3.14.A, minimizes potential consequences in the event of any postulated abnormal event during testing. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident From Any Previously Evaluated.
Technical Specifications currently allow for operation at greater than 212EF while imposing MODE 4 requirements in addition to the secondary containment requirements required to be met. No new operational conditions beyond those currently allowed by LCO 3.10.1 are introduced. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements or eliminate any existing requirements. The changes do
not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3The Proposed Change Does Not Involve a Significant Reduction in a Margin of Safety.
Technical Specifications currently allow for operation at greater than 212EF while imposing MODE 4 requirements in addition to the secondary containment requirements required to be met. This license amendment allows Pilgrim to implement LCO 3.14.A during the test, if the temperature appears to exceed 212EF, rather than implementing LCO 3.14.A at the start of the test. This provides operational flexibility but does not significantly reduce the margin of safety, as the licensee was already authorized to conduct the test at greater than 212EF. Allowing completion of inspections and testing and supporting completion of scram time testing initiated in conjunction with an inservice leak or hydrostatic test prior to power operation results in enhanced safe operations by eliminating unnecessary maneuvers to control reactor temperature and pressure.
Therefore, the proposed change does not involve a significant reduction.
Based on the above considerations, the NRC staff concludes that the amendment meets the three criteria of 10 CFR 50.92. Therefore, the NRC staff has made a final determination that the proposed amendment does not involve a significant hazards consideration.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Massachusetts State official was notified of the proposed issuance of the amendment. The State official had no comments.
6.0 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. 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 made a final finding that the amendment involves no significant hazards consideration. 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.
7.0 CONCLUSION
The Commission 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.
8.0 REFERENCES
- 1. NUREG-1433, General Electric Plants, BWR/4, Revision 3, Standard Technical Specifications (STS), August 31, 2003.
- 2. NUREG-1434, General Electric Plants, BWR/6, Revision 3, Standard Technical Specifications (STS), August 31, 2003.
- 3. Request for Additional Information (RAI) Regarding TSTF-484, April, 7, 2006, ADAMS accession number ML060970568.
- 4. Response to NRC RAIs Regarding TSTF-484, June 5, 2006, ADAMS accession number ML061560523.
- 5. TSTF-484 Revision 0, Use of TS 3.10.1 for Scram Times Testing Activities, May 5, 2005, ADAMS accession number ML052930102.
- 6. TSTF Response to NRC Notice for Comment, September 20, 2006, ADAMS accession number ML062650171.
Principal Contributor: T. Wertz Date: March 26, 2007
Pilgrim Nuclear Power Station cc:
Regional Administrator, Region I Secretary of Public Safety U. S. Nuclear Regulatory Commission Executive Office of Public Safety 475 Allendale Road One Ashburton Place King of Prussia, PA 19406-1415 Boston, MA 02108 Senior Resident Inspector Director, Massachusetts Emergency U. S. Nuclear Regulatory Commission Management Agency Pilgrim Nuclear Power Station Attn: James Muckerheide Post Office Box 867 400 Worcester Road Plymouth, MA 02360 Framingham, MA 01702-5399 Chairman, Board of Selectmen Mr. William D. Meinert 11 Lincoln Street Nuclear Engineer Plymouth, MA 02360 Massachusetts Municipal Wholesale Electric Company Chairman P.O. Box 426 Nuclear Matters Committee Ludlow, MA 01056-0426 Town Hall 11 Lincoln Street Mr. Kevin H. Bronson Plymouth, MA 02360 General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Chairman, Duxbury Board of Selectmen Pilgrim Nuclear Power Station Town Hall 600 Rocky Hill Road 878 Tremont Street Plymouth, MA 02360-5508 Duxbury, MA 02332 Mr. Michael A. Balduzzi Office of the Commissioner Site Vice President Massachusetts Department of Entergy Nuclear Operations, Inc.
Environmental Protection Pilgrim Nuclear Power Station One Winter Street 600 Rocky Hill Road Boston, MA 02108 Plymouth, MA 02360-5508 Office of the Attorney General Mr. Stephen J. Bethay One Ashburton Place Director, Nuclear Safety Assurance 20th Floor Entergy Nuclear Operations, Inc.
Boston, MA 02108 Pilgrim Nuclear Power Station 600 Rocky Hill Road Director, Radiation Control Program Plymouth, MA 02360-5508 Commonwealth of Massachusetts Executive Offices of Health and Mr. Bryan S. Ford Human Services Manager, Licensing 174 Portland Street Entergy Nuclear Operations, Inc.
Boston, MA 02114 Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
Pilgrim Nuclear Power Station cc:
Mr. Gary J. Taylor Mr. Michael J. Colomb Chief Executive Officer Director of Oversight Entergy Operations Entergy Nuclear Operations, Inc.
1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. John T. Herron Assistant General Counsel Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Ms. Stacey Lousteau Mr. Oscar Limpias Treasury Department Vice President, Engineering Entergy Services, Inc.
Entergy Nuclear Operations, Inc. 639 Loyola Avenue 440 Hamilton Avenue New Orleans, LA 70113 White Plains, NY 10601 Mr. James Sniezek Mr. Christopher Schwarz 5486 Nithsdale Drive Vice President, Operations Support Salisbury, MD 21801-2490 Entergy Nuclear Operations, Inc.
440 Hamilton Avenue Mr. Michael D. Lyster White Plains, NY 10601 5931 Barclay Lane Naples, FL 34110-7306 Mr. John F. McCann Director, Nuclear Safety Assurance Mr. Garrett D. Edwards Entergy Nuclear Operations, Inc. 814 Waverly Road 440 Hamilton Avenue Kennett Square, PA 19348 White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601