ML071550079

License Amendment, Issuance of Amendment Technical Specification 3.10.1, Inservice Leak and Hydrostatic Testing Operating, Consistent with TSTF-484

ML071550079
Person / Time
Site:	FitzPatrick
Issue date:	06/21/2007
From:	Boska J NRC/NRR/ADRO/DORL/LPLI-1
To:	Kansler M Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
TAC MD4582
Download: ML071550079 (13)

Text

June 21, 2007 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATION 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION, CONSISTENT WITH TECHNICAL SPECIFICATION TASK FORCE-484 (TAC NO. MD4582)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 288 to Facility Operating License No. DPR-59 for the James A. FitzPatrick Nuclear Power Plant. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated February 15, 2007.

The amendment revises TS Section 3.10.1, Inservice Leak and Hydrostatic Testing Operation, to expand its scope to include provisions for temperature excursions greater than 212 EF as a consequence of inservice leak or hydrostatic testing, and to allow performance of control rod scram time testing and other required testing when initiated in conjunction with the performance of an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This operating license improvement was made available by the Nuclear Regulatory Commission on October 27, 2006, as part of the consolidated line item improvement process.

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/

John P. Boska, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosures:

1. Amendment No. 288 to DPR-59

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

June 21, 2007 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATION 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION, CONSISTENT WITH TECHNICAL SPECIFICATION TASK FORCE-484 (TAC NO. MD4582)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 288 to Facility Operating License No. DPR-59 for the James A. FitzPatrick Nuclear Power Plant. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated February 15, 2007.

The amendment revises TS Section 3.10.1, Inservice Leak and Hydrostatic Testing Operation, to expand its scope to include provisions for temperature excursions greater than 212 EF as a consequence of inservice leak or hydrostatic testing, and to allow performance of control rod scram time testing and other required testing when initiated in conjunction with the performance of an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This operating license improvement was made available by the Nuclear Regulatory Commission on October 27, 2006, as part of the consolidated line item improvement process.

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/

John P. Boska, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosures:

1. Amendment No. 288 to DPR-59

2. Safety Evaluation cc w/encls: See next page Package No.: ML071730312 Amendment No.: ML071550079 Tech Spec No.: ML071760127 OFFICE LPL1-1/PE LPL1-1\PM LPL1-1\LA ITSB/BC LPL1-1\BC NAME DWoodyatt JBoska SLittle TKobetz MKowal as signed DATE 06/19/ 07 06/18/ 07 06/14 / 07 3/22/2007 06 /20/ 07 Official Record Copy

FitzPatrick Nuclear Power Plant cc:

Mr. Gary J. Taylor Manager, Licensing Chief Executive Officer Entergy Nuclear Operations, Inc.

Entergy Operations, Inc. 440 Hamilton Avenue 1340 Echelon Parkway White Plains, NY 10601 Jackson, MS 39213 Mr. Michael J. Colomb Mr. John T. Herron Director of Oversight 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 Mr. David Wallace Mr. Peter T. Dietrich Director, Nuclear Safety Assurance Site Vice President Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant James A. FitzPatrick Nuclear Power Plant P.O. Box 110 P.O. Box 110 Lycoming, NY 13093 Lycoming, NY 13093 Mr. James Costedio Mr. Kevin J. Mulligan Manager, Regulatory Compliance General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant James A. FitzPatrick Nuclear Power Plant P.O. Box 110 P.O. Box 110 Lycoming, NY 13093 Lycoming, NY 13093 Assistant General Counsel Mr. Oscar Limpias Entergy Nuclear Operations, Inc.

Vice President Engineering 440 Hamilton Avenue Entergy Nuclear Operations, Inc. White Plains, NY 10601 440 Hamilton Avenue White Plains, NY 10601 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Christopher Schwarz 475 Allendale Road Vice President, Operations Support King of Prussia, PA 19406 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue Resident Inspector's Office White Plains, NY 10601 James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission Mr. John F. McCann P.O. Box 136 Director, Licensing Lycoming, NY 13093 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison

FitzPatrick Nuclear Power Plant cc:

Mr. Charles Donaldson, Esquire Mr. Garrett D. Edwards Assistant Attorney General 814 Waverly Road New York Department of Law Kennett Square, PA 19348 120 Broadway New York, NY 10271 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Oswego County Administrator Mr. Steven Lyman 46 East Bridge Street Oswego, NY 13126 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. James H. Sniezek BWR SRC Consultant 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster BWR SRC Consultant 5931 Barclay Lane Naples, FL 34110-7306

DATED: June 21, 2007 AMENDMENT NO. 288 TO FACILITY OPERATING LICENSE NO. DPR-59 FITZPATRICK PUBLIC LPL1-1 R/F RidsNrrDorlLpl-1 RidsOGCMailCenter GHill (2)

RidsNrrDirsItsb TWertz RidsAcrsAcnwMailCenter RidsNrrPMJBoska RidsNrrLASLittle ECobey, RI cc: Plant Mailing list

ENTERGY NUCLEAR FITZPATRICK, LLC AND ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 288 License No. DPR-59

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

A. The application for amendment by Entergy Nuclear Operations, Inc. (the licensee) dated February 15, 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-59 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 288, are hereby incorporated in 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 its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Mark G. Kowal, 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: June 21, 2007

ATTACHMENT TO LICENSE AMENDMENT NO. 288 FACILITY OPERATING LICENSE NO. DPR-59 DOCKET NO. 50-333 Replace the following page of the 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 page of the Appendix A Technical Specifications 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 3.10.1-1 3.10.1-1

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 288 TO FACILITY OPERATING LICENSE NO. DPR-59 ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

By application dated February 15, 2007 (Agencywide Documents Access and Management Systems Accession No. ML070871160), Entergy Nuclear Operation, Inc. (Entergy, the licensee) requested changes to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant.

The proposed changes would revise Limiting Condition for Operation (LCO) 3.10.1 to expand its scope to include provisions for temperature excursions greater than 212 EF 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.

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 EF 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).

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 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 becomes 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 EF provided certain secondary containment LCOs are met.

TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities, modifies LCO 3.10.1 to allow a licensee to implement LCO 3.10.1, while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceed 212 EF during testing.

This modification does not alter current requirements for hydrostatic and leakage testing as required by Appendix G to 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. Criterion 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 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 (SR) to conduct scram time testing when certain conditions are met in order to ensure that Criterion 10 of Appendix A to 10 CFR Part 50 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 800 psig and prior to exceeding 40 percent rated thermal power (RTP).

TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities, would modify LCO 3.10.1 to allow SR 3.1.4.1 and SR 3.1.4.4 to be conducted in Mode 4 with average reactor coolant temperature greater than 212 EF. Scram time testing would be performed in accordance with LCO 3.10.4, Single Control Rod Withdrawal - Cold Shutdown. This modification to LCO 3.10.1 does not alter the means of compliance with Criterion 10 of Appendix A to 10 CFR Part 50.

3.0 TECHNICAL EVALUATION

The existing provisions of LCO 3.10.1 allow for hydrostatic and leakage testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 EF, while imposing Mode 3 secondary containment requirements. Under the existing provision, LCO 3.10.1 would have to be implemented prior to hydrostatic and leakage testing. As a result, if LCO 3.10.1 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 EF during the conduct of the hydrostatic and leakage test. TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities, modifies LCO 3.10.1 to allow a licensee to implement LCO 3.10.1, while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceed 212 EF during testing. 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 EF. Since the current LCO 3.10.1 allows testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 EF, the proposed change does not introduce any new operational conditions beyond those currently allowed.

SR 3.1.4.1 and SR 3.1.4.4 require that control rod scram time be tested at reactor steam dome pressure greater than or equal to 800 psig and before exceeding 40 percent rated thermal power (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 3.10.1 inservice leak or hydrostatic test, scram time testing must be suspended. Additionally, if LCO 3.10.1 is not implemented and average reactor coolant temperature exceeds 212 EF 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 LCO 3.10.1 to allow a licensee to complete scram time testing initiated during inservice leak or hydrostatic testing. As stated earlier, since the current LCO 3.10.1 allows testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 EF, 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 3.10.1 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 occurred. In addition, two low-pressure emergency core cooling systems (ECCS) injection/spray subsystems are required to be operable in Mode 4 by TS 3.5.2, ECCS-Shutdown. 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 3.10.1 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 3.10.1, minimizes potential consequences in the event of any postulated abnormal event during testing. In addition, the requested modification to LCO 3.10.1 does not create any new modes of operation or operating conditions that are not currently allowed. Therefore, the NRC staff finds the proposed change acceptable.

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. 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, and there has been no public comment on such finding (72 FR 17947). 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 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.

7.0 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: June 21, 2007