ML090780250
| ML090780250 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/09/2009 |
| From: | Polson K Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML090780250 (11) | |
Text
Keith J. Poison P.O. Box 63 ViceJ.
Presi Nne MLycoming, New York 13093 Vice President-Nine Mile Point 315.349.5200 315.349.1321 Fax 0Constellation Energy Nine Mile Point Nuclear Station March 9, 2009 U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 ATTENTION: Document Control Desk
SUBJECT:
Nine Mile Point Nuclear Station Unit No. 2; Docket No. 50-4 10 Application for Technical Specification Improvement to Revise Control Rod Scram Time Testing Frequency Gentlemen:
In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Nine Mile Point Nuclear Station, LLC (NMPNS) is submitting a request for an amendment to the technical specifications (TS) for Nine Mile Point Unit 2 (NMP2).
The proposed amendment would revise the TS testing frequency for the surveillance requirement (SR) in TS 3.1.4, "Control Rod Scram Times." These changes are based on TS Task Force (TSTF) change traveler TSTF-460-A (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 the frequency of SR 3.1.4.2, control rod scram time testing, from "120 days cumulative operation in MODE 1" to "200 days cumulative operation in MODE 1." A notice announcing the availability of this proposed TS change using the consolidated line item improvement process was published in the Federal Register on August 23, 2004 (69 FR 51864). provides a description of the proposed change and confirmation of applicability. provides the existing TS page marked-up to show the proposed change. provides the existing TS Bases pages marked-up to show the proposed change.
NMPNS requests approval of the proposed license amendment by September 30, 2009, with the amendment being implemented within 60 days.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York official.
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Document Control Desk March 9, 2009 Page 2 Should you have any questions regarding the information in this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219.
Very truly yours, STATE OF NEW YORK TO WIT:
COUNTY OF OSWEGO I, Keith J. Poison, being duly sworn, state that I am Vice President-Nine Mile Point, and that I am duly authorized to execute and file this request on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants.
Such information has been reviewed in accordance with company practice and I believe it to be reliable.
Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Oswego, this 'Y--day of _
q..-
.2009.
WITNESS my Hand and Notarial Seal:
4
.4ota/___ ublic______
Notary Public My Commission Expires:
SANDRA A. OSWALD Notary Public, State of New York
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No. 01OS6032276 Qualified in Oswego County Date Commission Expires 1 -.a-.-d7.!
KJP/GNS Attachments:
- 1. Description and Assessment
- 2. Proposed Technical Specification Change (Mark-up)
- 3. Proposed Technical Specification Bases Change (Mark-up) cc: S. J. Collins, NRC R. V. Guzman, NRC Resident Inspector, NRC J. P. Spath, NYSERDA
ATTACHMENT 1 DESCRIPTION AND ASSESSMENT 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0
10.0 INTRODUCTION
PROPOSED CHANGE BACKGROUND REGULATORY REQUIREMENTS AND GUIDANCE TECHNICAL ANALYSIS COMMITMENTS NO SIGNIFICANT HAZARDS CONSIDERATION ENVIRONMENTAL EVALUATION PRECEDENT REFERENCES Nine Mile Point Nuclear Station, LLC March 9, 2009
ATTACHMENT I DESCRIPTION AND ASSESSMENT
1.0 INTRODUCTION
The proposed license amendment revises the required testing frequency for the surveillance requirement (SR) in Technical Specification (TS) 3.1.4, "Control Rod Scram Times." A notice announcing the availability of this proposed TS change using the consolidated line item improvement process (CLIIP) was published in the Federal Register on August 23, 2004 (69 FR 51864).
2.0 PROPOSED CHANGE
These changes are based on TS Task Force (TSTF) change traveler TSTF-460-A, Rev. 0, "Control Rod Scram Time Testing Frequency," that has been approved generically for the boiling water reactor (BWR) Standard TS, NUREG-1433 (BWR/4) and NUREG-1434 (BWR/6). The required frequency of SR 3.1.4.2, control rod scram time testing, is changed from "120 days cumulative operation in MODE 1" to "200 days cumulative operation in MODE 1."
3.0 BACKGROUND
The background for this application is adequately addressed by the CLIIP Notice of Availability published on August 23, 2004 (69 FR 51864) and TSTF-460-A, Rev. 0.
4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the CLIIP Notice of Availability published on August 23, 2004 (69 FR 51864) and TSTF-460-A, Rev. 0.
5.0 TECHNICAL ANALYSIS
Nine Mile Point Nuclear Station, LLC (NMPNS) has reviewed the safety evaluation (SE) published on August 23, 2004 (69 FR 51864) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staff's SE and the supporting information provided to support TSTF-460-A, Rev. 0. NMPNS has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Nine Mile Point Unit 2 (NMP2) and justify this amendment for the incorporation of the changes into the NMP2 TS.
As described in the CLIIP model SE, part of the justification for the change in surveillance frequency is the high reliability of the NMP2 control rod drive system. As requested in the notice of availability published on August 23, 2004 (69 FR 51864), the historical performance of the control rod drive system at NMP2 is as follows:
The control rod insertion time test results at the NMP2 have shown the control rod scram rates to be highly reliable. During the most recent 7 years of operation, out of more than 1340 scram time tests, no 'Slow Rods' were identified. Improved Technical Specifications (ITS) 1 of 3
ATTACHMENT 1 DESCRIPTION AND ASSESSMENT were implemented at NMP2 in December, 2000 and Scram Time Testing (STT) for all Control Rod Drives (CRDs) from then up to present met the ITS acceptance criteria with no
'Slow Rods' identified. Prior to ITS, custom Technical Specifications (CTS) had different criteria using maximum and average scram times for detecting slow CRDs. Scram Time Testing conducted between 1998 and 2000 using CTS criteria were reviewed. No instance of slow scram times were identified during this period.
6.0 COMMITMENTS As discussed in the CLIIP model SE published in the Federal Register on August 23, 2004 (69 FR 51864) for this TS improvement, NMPNS is making the following regulatory commitment with the understanding that the NRC will include it as a condition for the issuance of the requested amendment:
NMPNS will incorporate the revised acceptance criterion value of 7.5 percent into the TS Bases for NMP2 in accordance With the Bases Control Program described in TS 5.5.10.
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7.0 NO SIGNIFICANT HAZARDS CONSIDERATION NMPNS has reviewed the proposed no significant hazards consideration determination published on August 23, 2004 (69 FR 51864) as part of the CLIIP. NMPNS has concluded that the proposed determination presented in the notice is applicable to NMP2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
8.0 ENVIRONMENTAL EVALUATION NMPNS has reviewed the environmental evaluation included in the model SE published on August 23, 2004 (69 FR 51864) as part of the CLIIP. NMPNS has concluded that the staffs findings presented in that evaluation are applicable to NMP2 and the evaluation is hereby incorporated by reference for this application.
9.0 PRECEDENT This application is being made in accordance with the CLIIP.
NMPNS is not proposing variations or deviations from the TS changes described in TSTF-460-A, Rev. 0, or the NRC staff s model SE published on August 23, 2004 (69 FR 51864).
10.0 REFERENCES
Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specifications Improvement Regarding Revision to the Control Rod Scram Time Testing Frequency in STS 3.1.4, "Control Rod Scram Times" for General Electric Boiling Water Reactors 2 of 3
ATTACHMENT I DESCRIPTION AND ASSESSMENT Using the Consolidated Line Item Improvement Process, published August 23, 2004 (69 FR 51864) 3 of 3
ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGE (MARK-UP)
Nine Mile Point Nuclear Station, LLC March 9, 2009
Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.1.4.2 Verify, for a representative sample, each 1-*1n'days tested control rod scram time is within the cumulative limits of Table 3.1.4-1 with reactor steam operation in dome pressure > 800 psig.
MODE I SR 3.1.4.3 Verify each affected control rod scram time Prior to is within the limits of Table 3.1.4-1 with declaring any reactor steam dome pressure.
control rod OPERABLE after work on control rod or CRD System that could affect scram time SR 3.1.4.4 Verify each affected control rod scram time Prior to is within the limits of Table 3.1.4-1 with exceeding reactor steam dome pressure Ž 800 psig.
40% RTP after fuel movement within the affected core cell AND Prior to exceeding 40%
RTP after work on control rod or CRD System that could affect scram time I
NMP2 3.1.4-2 Amendment-i-1-7
ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION BASES CHANGE (MARK-UP)
(FOR INFORMATION ONLY)
Nine Mile Point Nuclear Station, LLC March 9, 2009
Control Rod Scram Times B 3.1.4 BASES SURVEILLANCE core scram, the CRD pump head would be seen by all control REQUIREMENTS rods and would have a negligible effect on the scram (continued) insertion times.
SR 3.1.4.1 The scram reactivity used in DBA and transient analyses is based on assumed control rod scram time.
Measurement of the scram times with reactor steam dome pressure > 800 psig demonstrates acceptable scram times for the transients analyzed in References 5 and 6.
Maximum scram insertion times occur at a reactor pressure of approximately 800 psig because of the competing effects of reactor steam dome pressure and stored accumulator energy.
Therefore, demonstration of adequate scram times at reactor steam dome pressure.> 800 psig ensures that the scram times will be within the specified limits at higher pressures.
Limits are specified as a function of reactor pressure to account for the sensitivity of the scram insertion times with pressure and to allow a range of pressures over which scram time testing can be performed.
To ensure scram time testing is performed within a reasonable time following a shutdown > 120 days, control rods are required to be tested before exceeding 40% RTP.
This Frequency is acceptable, considering the additional Surveillances performed for control rod OPERABILITY, the frequent verification of adequate accumulator pressure, and the required testing of control rods affected by fuel movement within the associated core cell and by work on control rods or the CRD System.
SR 3.1.4.2 Additional testing of a sample of control rods is required to verify the continued performance of the scram function during the cycle.
A representative sample contains at least 10% of the control rods.
The sample remains representative if no more than--j2*
of the control rods in the sample tested
.. are determi-ned to be "slow."
If more than "98-of the sample i
de-'*s clared to be "slow' per**ec--riteria in Table 3.1.4-1,
`-,__addit-ional -coýtrol-rods are _-tested until t-h-is d criterion (i.e?:A.2e of the entire sample size) is satisfied, or until the total number of "slow" control rods (throughout the core, from all Surveillances) exceeds the LCO limit.
For (continued)
NMP2 B 3.1.4-4 Revision-0G-
Control Rod Scram Times B 3.1.4 BASES SURVEILLANCE SR 3.1.4.2 (continued)
REQUIREMENTS planned testing, the control rods selected for the sample should be different for each test.
Data from inadvertent scrams should be used whenever possible to avoid unnecessary testing at power, even if the control rods with data were previously tested in a sample.
T h e
<-day-Frequency -s Q(
based on operating experience that has shown control rod scram times do not significantly change over an operating cycle.
This Frequency is also reasonable, based on the additional Surveillances done on the CRDs at more frequent intervals in accordance with LCO 3.1.3 and LCO 3.1.5, "Control Rod Scram Accumulators."
SR 3.1.4.3 When work that could affect the scram insertion time is performed on a control rod or the CRD System, testing must be done to demonstrate that each affected control rod retains adequate scram performance over the range of applicable reactor pressures from zero to the maximum permissible pressure.
The scram testing must be performed once before declaring the control rod OPERABLE.
The required scram time testi.ng must demonstrate that the affected control rod is still within acceptable limits.
The scram time limits for reactor pressures < 800 psig are found in the Technical Requirements Manual (Ref.
- 9) and are established based on a high probability of meeting the acceptance criteria at reactor pressures > 800 psig.
Limits for reactor pressures > 800 psig are found in Table 3.1.4-1.
If testing demonstrates the affected control rod does not meet these limits, but is within 7-second limit of Table 3.1.4-1, Note 2, the control rod can be declared OPERABLE and "slow."
Specific examples of work that could affect the scram times include (but are not limited to) the following:
removal of any CRD for maintenance or modification; replacement of a control rod; and maintenance or modification of a scram solenoid pilot valve, scram valve, accumulator isolation valve, or check valves in the piping required for scram.
(continued)
NMP2 B 3.1.4-5 Revision--Oý