ML081710050

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License Amendment Revision of Rod Worth Minimizer Limiting Condition for Operation During Startup
ML081710050
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 07/29/2008
From: Richard Guzman
NRC/NRR/ADRO/DORL/LPLI-1
To: Polson K
Nine Mile Point
Guzman R
Shared Package
ML081850531 List:
References
TAC MD6215
Download: ML081710050 (16)
v • d • e


Text

July 29, 2008 Mr. Keith J. Polson 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: REVISION OF ROD WORTH MINIMIZER LIMITING CONDITION FOR OPERATION DURING STARTUP (TAC NO. MD6215)

Dear Mr. Polson:

The Commission has issued the enclosed Amendment No. 196 to Renewed 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 July 23, 2007, as supplemented by letter dated January 24, 2008.

The amendment revises the NMP-1 TS Section 3.1.1, Control Rod System, to incorporate a provision that should the rod worth minimizer (RWM) become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup will be allowed to continue. This provision will rely on the RWM function being performed manually and will require a double check of compliance with the control rod program by a second licensed operator or other qualified member of the technical staff. The use of this allowance will be limited to one startup in the last calendar year.

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/

Richard V. Guzman, 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. 196 to DPR-63
2. Safety Evaluation cc w/encls: See next page

July 29, 2008 Mr. Keith J. Polson 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: REVISION OF ROD WORTH MINIMIZER LIMITING CONDITION FOR OPERATION DURING STARTUP (TAC NO. MD6215)

Dear Mr. Polson:

The Commission has issued the enclosed Amendment No. 196 to Renewed 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 July 23, 2007, as supplemented by letter dated January 24, 2008.

The amendment revises the NMP-1 TS Section 3.1.1, Control Rod System, to incorporate a provision that should the rod worth minimizer (RWM) become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup will be allowed to continue. This provision will rely on the RWM function being performed manually and will require a double check of compliance with the control rod program by a second licensed operator or other qualified member of the technical staff. The use of this allowance will be limited to one startup in the last calendar year.

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/

Richard V. Guzman, 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. 196 to DPR-63
2. Safety Evaluation cc w/encls: See next page Package No.: ML081850531 Amendment No.: ML081710050 Tech Spec No.: ML
  • SE provided by memo. No substantial changes made. NRR-058 OFFICE LPLI-1/PM LPLI-1/LA SRXB/BC* ITSB/BC OGC LPLI-1/BC NAME RGuzman SLittle GCranston RElliott MSimon MKowal DATE 7/24/08 7/28/08 3/17/08 SE DTD 7/24/08 7/14/08 7/29/08 OFFICIAL RECORD COPY

DATED: July 29, 2008 AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-63 NINE MILE POINT, UNIT NO. 1 PUBLIC LPLI-1 MKowal RidsNrrDorlLpI-1 SLittle RidsNrrLASLittle RGuzman RidsNrrPMRGuzman RJervey RidsNrrDpr OGC RidsOgcMailCenter GHill (2)

GCranston RidsNrrDssSrxb EElliott RidsNrrDirsItsb ACRS RidsNrrAcrsAcnwMailCenter GDentel, RI RidsRgn1MailCenter MRazzaque cc: Plant Service list

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

Mr. Michael J. Wallace, Vice-Chairman Mark J. Wetterhahn, Esquire Constellation Energy Winston & Strawn 100 Constellation Way, Suite 1800P 1700 K Street, NW Baltimore, MD 21202 Washington, DC 20006 Mr. Henry B. Barron, President, CEO & Carey W. Fleming, Esquire Chief Nuclear Officer Sr. Counsel - Nuclear Generation Constellation Energy Nuclear Group, LLC Constellation Energy Nuclear Group, LLC 100 Constellation Way, Suite 200C 750 East Pratt Street, 17th Floor Baltimore, MD 21202 Baltimore, MD 21202 Mr. Terry F. Syrell Mr. John P. Spath Director, Licensing New York State Energy, Research, and Nine Mile Point Nuclear Station Development Authority P.O. Box 63 17 Columbia Circle Lycoming, NY 13093 Albany, NY 12203-6399 Regional Administrator, Region I Mr. Paul Tonko U.S. Nuclear Regulatory Commission President and CEO 475 Allendale Road New York State Energy, Research, and King of Prussia, PA 19406 Development Authority 17 Columbia Circle Resident Inspector Albany, NY 12203-6399 U.S. Nuclear Regulatory Commission P.O. Box 126 Mr. Gary L. Detter Lycoming, NY 13093 Manager - Nuclear Safety and Security 100 Constellation Way, Suite 200C Supervisor Baltimore, MD 21202 Town of Scriba Route 8, Box 382 Oswego, NY 13126 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Paul D. Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223

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. 196 Renewed 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 July 23, 2007, as supplemented by letter dated January 24, 2008, 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 Renewed 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. 196, 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 within 60 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: July 29, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-63 DOCKET NO. 50-220 Replace the following page of the Renewed 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 31a 31a 32 32

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-63 NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-220

1.0 INTRODUCTION

By letter dated July 23, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072120587), as supplemented by letter dated January 24, 2008 (ADAMS Accession No. ML080250162), Nine Mile Point Nuclear Station (NMPNS), LLC (the licensee) submitted a license amendment request (LAR) for Nine Mile Point, Unit No. 1 (NMP1).

The proposed amendment revises Technical Specification (TS) Section 3.1.1, Control Rod System, to incorporate a provision that should the rod worth minimizer (RWM) become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup will be allowed to continue. This provision will rely on the RWM function being performed manually and will require a double check of compliance with the control rod program by a second licensed operator or other qualified member of the technical staff. The use of this allowance will be limited to one startup in the last calendar year.

The supplemental letter dated January 24, 2008, 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 initial proposed no significant hazards consideration determination as published in the Federal Register on September 11, 2007 (72 FR 51863).

Currently, TS Section 3.1.1.b(3)(b) requires the RWM to be operable whenever the reactor is in the startup or run mode and rated thermal power is below 10%. If the RWM fails after 12 or more control rods have been withdrawn, TS Section 3.1.1.b(3)(b) allows startup to continue using a second independent operator or engineer to verify that the operator at the reactor console is following the control rod program. As required by TS Section 3.1.1.f., if the RWM fails prior to complete withdrawal of the first 12 control rods, the control rods must be re-inserted in order to achieve the hot shutdown condition. The proposed change, therefore, would increase flexibility in the RWM limiting conditions for operation by allowing reactor startup to proceed with (1) the RWM inoperable and (2) less than 12 control rods withdrawn, subject to a limitation on the frequency that this allowance can be used.

The licensee provided the following background information in its July 23, 2007, application:

Control rods provide the primary means for control of reactivity changes. Control rod block instrumentation includes channel sensors, logic circuitry, switches, relays, and computer equipment that are designed to ensure that specified fuel design limits are not exceeded for postulated transients and accidents.

The RWM is a computer controlled system designed to monitor and block, when necessary, operator control rod selection, withdrawal and insertion actions, and thus assist in preventing significant control rod pattern errors which could lead to a control rod with a high reactivity worth. A significant pattern error is one of several abnormal events, all of which must occur to have a control rod drop accident (CRDA) which might exceed fuel energy density limit criteria for the event. The RWM is used only during low power operation when a CRDA might be of significance. During low power operation, the RWM provides rod blocks upon detection of a significant pattern error. . . Because a significant CRDA can only occur at low power, the RWM constraints are automatically removed above 10% rated thermal power (RTP). A keylock switch in the control room permits the RWM to be bypassed in the event of equipment failure.

Operability of the RWM is required whenever the reactor is in the startup or run modes below 10% RTP. When thermal power is greater than 10% RTP, there is no possible control rod configuration that results in a control rod worth that could lead to the 280 cal/gm fuel damage limit being exceeded should a postulated CRDA occur.

With the RWM inoperable during a reactor startup, the operator is still capable of enforcing the prescribed control rod sequence. Therefore, if the RWM fails after 12 or more control rods have been withdrawn, TS Section 3.1.1.b(3)(b) allows for the RWM function to be performed manually and requires a double check of compliance with the control rod program by a second independent operator or engineer. The RWM may be bypassed under these conditions to allow continued operations. However, TS Section 3.1.1.b(3)(b) does not contain a similar allowance for the failure of the RWM prior to commencing rod withdrawal or prior to completion of withdrawal of the first 12 control rods.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance which the NRC staff considered in its review of the application are as follows:

  • 10 CFR 50.36, Technical specifications, which provides the regulatory requirements for the content required in a licensee TS. 10 CFR 50.36(d)(3) requires, in part, that the TS will include Surveillance Requirements (SR) to assure that the limiting conditions for operation (LCO) will be met.

not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences (AOOs).

The proposed TS changes are consistent with the RWM operability requirements contained in NUREG-1433, "Standard Technical Specifications - General Electric Plants, BWR/4," Revision 3.1. The NRC has previously approved similar amendments for other boiling-water reactors.

3.0 TECHNICAL EVALUATION

3.1 Proposed Change As stated by the licensee in its July 23, 2007, application:

The proposed change would revise TS Section 3.1.1.b(3)(b) to incorporate a provision that should the RWM become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup would be allowed to continue provided a second licensed operator or other qualified member of the technical staff verifies that the operator at the reactor console is following the control rod program, and provided that startup with the RWM inoperable has not previously been performed in the last calendar year.

Associated formatting and editorial changes would also be made to accommodate incorporation of this new provision.

The new TS Section 3.1.1.b(3)b would be revised to state as follows:

Whenever the reactor is in the startup or run mode below 10% rated thermal power, no control rods shall be moved unless the rod worth minimizer is operable, except as noted in 4.1.1.b(3)(a)(iv), or as follows:

If the rod worth minimizer becomes inoperable after the first 12 control rods have been withdrawn, continue startup provided that a second licensed operator or other qualified member of the technical staff verifies that the licensed operator at the reactor console is following the control rod program.

If the rod worth minimizer becomes inoperable before a startup is commenced or before the first 12 control rods have been withdrawn, continue startup provided that a startup with the rod worth minimizer inoperable has not been performed in the last calendar year, and provided that a second licensed operator or other qualified member of the technical staff verifies that the licensed operator at the reactor console is following the control rod program.

The new TS Section 4.1.1.b(3)b would be revised to state as follows:

If the rod worth minimizer is inoperable while the reactor is in the startup or run mode below 10% rated thermal power and a second licensed operator or other qualified member of the technical staff is being used he shall verify that all rod positions are correct prior to commencing withdrawal of each rod group.

The NRC staff determined it was appropriate to retain, in part, the existing wording in TS Section 3.1.1.b(3)(b): except as noted in 4.1.1.b(3)(a)(iv), in lieu of the requested insert 1(i):

Surveillance Requirement 4.1.1.b(3)(a)(iv) may be performed to demonstrate operability of the rod worth minimizer, as originally proposed by the licensee. The NRC staff considers this an administrative change that clarifies the TSs, maintains consistency with the existing format of NMP1 TSs, and does not change the technical content of the new provision as originally proposed in the licensees application dated July 23, 2007.

3.2 NRC Staff Evaluation The licensee provided the following technical analysis in its July 23, 2007, application:

As noted above, the RWM is designed to aid the operator by not allowing control rod patterns that are not part of the control rod program. This function can also be performed using a second qualified individual (i.e., licensed operator or qualified member of the technical staff) to verify movement of the control rods in the correct sequence. However, TS Section 3.1.1.b(3)(b) presently allows the use of a second qualified individual only in those cases when the RWM becomes inoperable after at least 12 control rods have been withdrawn.

The RWM enforces the control rod program to ensure that the initial conditions of the CRDA analysis are not violated. The CRDA involves multiple failures to initiate the event, including: (1) control rod becomes decoupled from the control rod drive; (2) the decoupled control rod becomes stuck in the fully inserted position after its drive mechanism has been withdrawn; and (3) the control rod becomes un-stuck and drops out of the core. The accident is terminated by a reactor scram on high neutron flux. The radiological consequences of the CRDA, presented in NMP1 Updated Final Safety Analysis Report (UFSAR) Section XV-C.4.0, are a small fraction of the guideline values of 10 CFR [Part] 100.

The proposed change revises TS Section 3.1.1.b(3)(b) to incorporate a provision that should the RWM become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup would be allowed to continue provided a second licensed operator or other qualified member of the technical staff verifies that the operator at the reactor console is following the control rod program, and provided that startup with the RWM inoperable has not been performed in the last calendar year (i.e., the last 12 months). This provision is similar in concept to the RWM operability requirements contained in NUREG-1433, Standard Technical Specifications, General Electric Plants, BWR/4, Revision 3.1 (STS 3.3.2.1, Condition C). Limiting the use of this allowance to once in the last calendar year minimizes the number of reactor startups initiated with the RWM out of service. It was developed as a result of the NRC review and acceptance of NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," Revision 8, Amendment 17.

By letter dated November 27, 2007, the NRC staff requested the licensee to describe the process by which it is determined and assured that a startup with the RWM inoperable was not performed in the last calendar year. The staff also requested the licensee to clarify, if the RWM is declared inoperable, what process is employed to determine the reason for the failure of the

RWM and what corrective actions are taken. In its supplemental response dated January 24, 2008, the licensee stated that [o]perators are directed to verify, by administrative methods, that startup with the RWM inoperable, has not been performed in the last 12 months. The current verification practice is to review the previous 12 months operator logs. This practice will be continued by the control room operators at NMP1. The licensee further stated that [t]he NMPNS Corrective Action Program is the primary day-to-day method for site identification of issues/concerns and determination of resolution effectiveness, and that the program also provides prompt identification, documentation, evaluation, and correction of conditions consistent with industry best practices. The items that are entered into the corrective action program are available for NRC review.

The licensee further stated in its July 23, 2007, application:

The verification process performed by the second qualified individual is controlled procedurally to ensure a high-quality, independent review of control rod movement. This process performs the same function as the RWM performs; i.e.,

to provide protection against an operator error resulting in violation of the control rod program. The same verification process would be employed whether the number of control rods withdrawn is more or less than 12 when the RWM becomes inoperable. Since the control rod program will continue to be enforced by either the RWM or verification by a second qualified individual, the initial conditions of the CRDA radiological consequence analysis presented in the UFSAR are not altered. In addition, the proposed change does not have any impact on either (1) the probability of occurrence of any of the failures that are necessary for a CRDA to occur, or (2) systems and components assumed to operate to mitigate the accident (e.g., reactor protection system instrumentation).

The second qualified individual is currently described in TS Sections 3.1.1.b(3)(b) and 4.1.1.b(3)(b) as "a second independent operator or engineer." This description is revised to "a second licensed operator or other qualified member of the technical staff," consistent with NUREG-1433. This is an administrative change that does not alter the requirement that the individual must possess appropriate qualifications to perform the independent verification of proper control rod movement.

The NRC staff has reviewed the licensees LAR application along with the supporting documentation, including responses to the staffs request for additional information. The review of TS changes in this safety evaluation was performed to evaluate the changes that would allow a revision to TS Section 3.1.1.b(3)(b) to incorporate a provision that should the RWM become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup would be allowed to continue provided a second licensed operator or other qualified member of the technical staff verifies that the operator at the reactor console is following the control rod program, and provided that startup with the RWM inoperable has not previously been performed in the last calendar year.

Based on its review, the NRC staff concludes that the proposed TS changes are acceptable because (1) the verification process performed by the second qualified individual will ensure independent review of control rod movement, and will provide protection against an operator error, (2) limiting the use of this allowance to once in the last calendar year will minimize the

number of reactor startups initiated with the RWM out of service, and (3) the proposed change is consistent with the NUREG-1433 and NEDE-24011-P-A, the NRC-approved GESTAR 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 amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (72 FR 51863). Accordingly, the amendments meet 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 amendments.

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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: M. Razzaque R. Grover C. Schulten Date: July 29, 2008

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