BVY 12-085, Technical Specifications Proposed Change No. 302 Inoperable Control Rods

Technical Specifications Proposed Change No. 302 Inoperable Control Rods

ML12356A297
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	12/17/2012
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 12-085, NUREG-1433, Rev 4
Download: ML12356A297 (15)

Text

En &W Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 12-085 December 17, 2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Technical Specifications Proposed Change No. 302 Inoperable Control Rods Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

Dear Sir or Madam:

In accordance with 10CFR50.90, Vermont Yankee (VY) is proposing an amendment to the Renewed Facility Operating License, DPR-28. The proposed change would revise VY Technical Specification (TS) 3.3.8 to provide an action statement for inoperable control rods in accordance with the similar Standard Technical Specifications (STS) provision (NUREG-1433, Revision 4).

VY has reviewed the proposed amendment in accordance with 1 OCFR50.92 and concludes it does not involve a significant hazards consideration. In accordance with 1 OCFR50.91, a copy of this application, with attachments, is being provided to the State of Vermont, Department of Public Service. to this letter provides a detailed description and evaluation of the proposed change. contains a markup of the current TS and Bases pages. Attachment 3 contains the retyped TS and Bases pages. Bases changes are provided for information only.

VY requests a 60 day implementation period from the date of amendment approval.

There are no new regulatory commitments made in this letter.

If you have any questions or require additional information pertaining to this submittal, please contact Mr. Robert Wanczyk at 802-451-3166.

Pbl 0 a-

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 17, 2012.

Sincerely,

[CJW/JTM]

Attachments:

1. Description and Evaluation of the Proposed Changes

2. Markup of the Current Technical Specifications and Bases Pages

3. Retyped Technical Specifications and Bases Pages cc:

Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Mr. Richard Guzman, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd Vernon, Vermont 05354 Ms. Elizabeth Miller, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 12-085 Docket No. 50-271 Vermont Yankee Nuclear Power Station Proposed Change 302 Inoperable Control Rods Description and Evaluation of Proposed Changes

BVY 12-085 / Attachment 1 / page 1 of 5

1.

SUMMARY

DESCRIPTION This evaluation supports a request by Vermont Yankee (VY) to amend Renewed Facility Operating License DPR-28.

The proposed amendment to the VY Technical Specifications (TS) would revise TS 3.3, Control Rod System, Section B, Control Rods, to provide action statements for inoperable control rods in accordance with similar actions specified in Improyed Standard Technical Specifications (STS)

(Reference 6.a).

This change was identified as an improvement opportunity during our review and investigation of General Electric Hitachi (GEH) issued 10CFR21, Communication SC 11-05, "Failure to Include Seismic Input in Channel-Control Blade Interference Customer Guidance."

The following changes are being proposed:

Renumber existing TS Section 3.3.B.6 to be 3.3.B.7

" Add a new paragraph (3.3.B.6) to TS to provide action statements for inoperable control rods, if inoperable for reasons other than specified in other sections of TS 3.3.

Surveillance requirements 4.3.B.6 and 4.3.B.7 were previously deleted and this change will simply remove those empty placeholder paragraphs.

" Revise the associated TS Bases to account for the added and re-numbered paragraphs.

2.

DETAILED DESCRIPTION The following changes are proposed to TS Section 3.3.B.3:

Current TS 3.3.B.6

6. If the above specifications are not satisfied, an orderly shutdown shall be initiated and the reactor shall be in the HOT SHUTDOWN condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Proposed TS 3.3.B.6 and 3.3.B.7

6. One or more control rods inoperable for reasons other than those specified in 3.3.A, 3.3.C or 3.3.D.

NOTE:

RWM may be bypassed as allowed by LCO 3.3.B.3, if required, to allow insertion of inoperable control rods and continued operation.

(a) Fully insert inoperable control rod within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, AND (b) Disarm the associated CRD within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

BVY 12-085 / Attachment 1 / page 2 of 5 Current TS 3.3.B.6 Bases (in part)

6. The action statement for TS 3.3.B.6 requires that the plant be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the required actions of TS 3.3.B.1 through 3.3.B.5 are not satisfied.

7. If the above specifications are not satisfied, an orderly shutdown shall be initiated and the reactor shall be in the HOT SHUTDOWN condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Proposed TS 3.3.B.6 and 3.3.B.7 Bases (in part)

6. With one or more control rods inoperable for reasons other than those specified in 3.3.A, 3.3.C or 3.3.D, operation may continue, provided the control rods are fully inserted within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and disarmed (electrically or hydraulically) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Inserting a control rod ensures the shutdown and scram capabilities are not adversely affected.

The control rod is disarmed to prevent inadvertent withdrawal during subsequent operations. The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves.

The control rods can be electrically disarmed -by disconnecting power from all four directional control valve solenoids.

Required Action 3.3.B.6 is modified by a note, which allows the RWM to be bypassed, if required, to allow insertion of the inoperable control rods and continued operation. LCO 3.3.B.3 provides additional requirements when the RWM is bypassed to ensure compliance with the CRDA analysis.

7. The action statement for TS 3.3.B.7 requires that the plant be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the required actions of TS 3.3.B.1 through 3.3.B.6 are not satisfied.

BVY 12-085 / Attachment 1 / page 3 of 5

3.

TECHNICAL EVALUATION Control rods are components of the Control Rod Drive (CRD) system, which is the primary reactivity control system for a boiling water reactor. The control rods enter the core from the bottom and contain a neutron absorber material that interrupts the fission process when inserted into the fuel region. In conjunction with the Reactor Protection System and the CRD System, the control rods provide the means for reliable control of reactivity changes to ensure under conditions of normal operation, including anticipated operational occurrences, that specified acceptable fuel design limits are not exceeded. In addition, the control rods provide the capability to hold the reactor core subcritical under all conditions and to limit the potential amount and rate of reactivity increase caused by a malfunction in the CRD system. The CRD system at Vermont Yankee consists of 89 control rod drive mechanisms and a hydraulic control unit for each drive mechanism.

As described in VY Updated Final Safety Analysis Report (UFSAR) Section 3.6.4.1 the Control Rods "shall be of such number and reactivity worths that the insertion of all but the control rod of highest worth is sufficient to make the reactor subcritical at any time during core life."

The operability of a control rod can be based upon a combination of factors, such as the ability to move the control rod and at what speed it inserts into the core. Some of these aspects are already identified and have appropriate action statements in their respective VY TS sections. For example, section 3.3.A covers reactivity margin and stuck control rods. Section 3.3.C addresses scram insertion times and section 3.3.D covers control rod accumulator operation. These sections already have appropriate limiting conditions for operation and action statements. There could however, be other circumstances which result in control rods being declared inoperable. The VY TS in section 3.3.8, "Control Rods," does not have a provision, similar to what is contained in BWR STS for this. This change proposes to add an action statement, similar to the provision contained in STS for inoperable control rods into section 3.3.B.

The new proposed wording would allow continued operation with an inoperable control rod, provided the control rod(s) are fully inserted within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and disarmed (electrically or hydraulically) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Inserting the control rod ensures the shutdown and scram capabilities are not adversely affected. The control rod is disarmed to prevent inadvertent withdrawal during subsequent operations. If this cannot be performed, then the existing shutdown action statement is invoked, which requires a reactor hot shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed completion times are consistent with STS, reasonable, and provide time to insert and disarm the control rods in an orderly manner and without unnecessarily challenging plant systems. These allowed completion times are also consistent with those already contained in current TS sections 3.3.C.3 and 3.3.C.4 for scram insertion times.

The imposition of an additional action statement for inoperable control rods, not otherwise already specified in existing TS, provides guidance to operators and assurance that the station will be operated within its design and licensing basis.

Additionally, the TS Bases are revised for section 3.3.B.6 and a new Bases section 3.3.B.7 is added to conform with the changes and new paragraph numbers assigned.

BVY 12-085 / Attachment 1 / page 4 of 5

4.

REGULATORY EVALUATION Vermont Yankee (VY) proposes to revise VY Technical Specification (TS) 3.3.B and associated Bases to provide an additional action statement for inoperable control rods. The new action statement was developed in accordance with similar actions contained in the applicable industry guidance, Improved Standard Technical Specifications (NUREG-1433) and applies to conditions that might result in inoperable control rods, for reasons other than those already specified in TS 3.3. The new and restrictive action statement, in accordance with accepted industry guidance, is conservative relative to the existing requirements in VY TS.

4.1 Significant Hazards Consideration Pursuant to 1 OCFR50.92, Vermont Yankee (VY) has reviewed the proposed change and concludes that the change does not involve a significant hazards consideration since the proposed change satisfies the criteria in 1 OCFR50.92(c). These criteria require that operation of the facility in accordance with the proposed 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 proposed change would revise the VY Technical Specification (TS) 3.3.B to provide an action statement for inoperable control rods similar to the actions recommended in the Standard Technical Specifications (STS).

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

1.

Does the Proposed amendment involve a significant increase in the Probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment does not significantly increase the probability or consequences of an accident. The adding of an additional, restrictive action statement for inoperable equipment, consistent with the STS does not alter any accident analysis. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment does not involve any new modes of operation. The change establishes additional restrictive controls for equipment that is considered inoperable. The proposed amendment does not change how the control rod system is operated or change the design configuration of the control rods. No new accident precursors are introduced. No new or different types of equipment will be installed. The methods governing plant operation remain bounded by current safety analysis assumptions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

BVY 12-085 / Attachment 1 / page 5 of 5

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed amendment does not involve any new methods of operation. The change establishes additional restrictive controls for equipment that is considered inoperable. The proposed amendment does not change how the control rod system is operated or change the design configuration of the control rods. No new or different types of equipment will be installed. The methods governing plant operation remain bounded by current safety analysis assumptions. Therefore, the proposed amendment will not involve a significant reduction in the margin of safety.

Based on the above, Entergy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.

ENVIRONMENTAL CONSIDERATIONS This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10CFR51.22(c)(9) as follows:

(i)

The amendment involves no significant hazards determination.

As described in Section 4 of this evaluation, the proposed change involves no significant hazards consideration.

(ii)

There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed amendment does not involve any physical alterations to the plant configuration that could lead to a change in the type or amount of effluent release offsite.

(iii)

There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, VY concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 1 OCR51.22(c)(9). Pursuant to 1 OCR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

6.

REFERENCES

a. NUREG-1433 "Standard Technical Specifications General Electric Plants, BWR/4,"

Volume 1, Revision 4

BVY 12-085 Docket 50-271 Vermont Yankee Nuclear Power Station Proposed Change 302 Inoperable Control Rods Markup of the Current Technical Specifications and Bases Pages

VYNPS 3.3 LIMITING CONDITIONS FOR OPERATION 4.3 SURVEILLANCE REQUIREMENTS (c)

Out-of-sequence control rods in each distinct RWM group shall be selected and the annunciator of the selection errors verified.

(d)

An out-of-sequence control rod shall be withdrawn no more than three notches and the rod block function verified.

4.

The control rod pattern and sequence of withdrawal or insertion shall be verified to comply with Specification 3.3.B.4.

4.

Control rod patterns and the sequence of withdrawal or insertion shall be established such that the rod drop accident limit of 280 cal/g is not exceeded.

5.

Control rods shall not be withdrawn for startup or refueling unless at least two source range channels have an

5.

Prior to withdraw or durin verifica made tha greater than or equal to have an three counts per second, rate of counts p If the above specifications are not satisfied, an orderly shutdown shall be initiated and the reactor shall be in the HOT SHUTDOWN condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

.o,,

w

+%obera S

%,.A--,4,

("-&)

1 wsa*

~

w

%6fatt;.'o 3 Inkc1 J

,,-)

't, A

,1'A *.V.*,

Ae e

No.

Z, control rod al for startup g refueling, tion shall be t at least two ange channels observed count at least three er second.

I 84

VYNPS BASES:

3.3 & 4.3 (Cont'd)

2.

The control rod housing support restricts the outward movement of a control rod to less than 3 inches in the extremely remote event of a housing failure.

The amount of reactivity which could be added by this small amount of rod withdrawal, which is less than a normal single withdrawal increment, will not contribute to any damage of the primary coolant system.

The design basis is given in Subsection 3.5.2 of the FSAR, and the design evaluation is given in Subsection 3.5.4.

This support is not required if the reactor coolant system is at atmospheric pressure since there would then be no driving force to rapidly eject a drive housing.

3.

In the course of performing normal startup and shutdown procedures, a pre-specified sequence for the withdrawal or insertion of control rods is followed.

Control rod dropout accidents which might lead to significant core damage, cannot occur if this sequence of rod withdrawals or insertions is followed.

The Rod Worth Minimizer restricts withdrawals and insertions to those listed in the pre-specified sequence and provides an additional check that the reactor operator is following prescribed sequence.

Although beginning a reactor startup without having the RWM operable would entail unnecessary risk, continuing to withdraw rods if the RWM fails subsequently is acceptable if a second licensed operator verifies the withdrawal sequence.

Continuing the startup increases core power, reduces the rod worth and reduces the consequences of dropping any rod.

Withdrawal of rods for testing is permitted with the RWM inoperable, if the reactor is subcritical and all other rods are fully inserted.

Above 17% power, the RWM is not needed since even with a single error an operator cannot withdraw a rod with sufficient worth, which if dropped, would result in anything but minor consequences.

4.

Refer to the "General Electric Standard Application for Reactor Fuel (GESTAR II)," NEDE-24011-P-A, (the latest NRC-approved version will be listed in the COLR).

5.

The Source Range Monitor (SRM) system provides a scram function in noncoincident configuration.

it does provide the operator with a visual indication of neutron level.

The consequences of reactivity accidents are a function of the initial neutron flux.

The requirement of at least three counts per second assures that any A

neMo transient, should it occur, begins at or above the initial value of 10- of rated power used in the analyses of transients from cold conditions.

One operable SRM channel is adequate to monitor the

%approach to criticality, therefore, two operable SRM's are specified for added conservatism.

4 The action statement for 3.3.BOrequires that the plant be placed in HOT SHUTDOWN w hin 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the required actions of CV TS 3.3.B.1 through 3.3.B ware not satisfied.

This ensures that all insertable control rods are inserted and places the reactor in a condition that does not require the active function (i.e., scram) of the control rods.

The allowed completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based upon operating experience to reach HOT SHUTDOWN from full power in an orderly manner and without challenging plant systems.

Amiendmuent No.

4&, ;4, 14-", flV-O994!1!, BVV 01-4#, Q", 233 g90

6. With one or more control rods inoperable for reasons other than those specified in 3.3.A, 3.3.C or 3.3.D, operation may continue, provided the control rods are fully inserted within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and disarmed (electrically or hydraulically) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Inserting a control rod ensures the shutdown and scram capabilities are not adversely affected. The control rod is disarmed to prevent inadvertent withdrawal during subsequent operations. The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves. The control rods can be electrically disarmed by disconnecting power from all four directional control valve solenoids. Required action 3.3.B.6 is modified by a note, which allows the RWM to be bypassed, if required, to allow insertion of the inoperable control rods and continued operation. LCO 3.3.13.3 provides additional requirements when the RWM is bypassed to ensure compliance with the CRDA analysis.

BVY 12-085 Docket 50-271 Vermont Yankee Nuclear Power Station Proposed Change 302 Inoperable Control Rods Retyped Technical Specifications and Bases Pages

VYNPS 3.3 LIMITING CONDITIONS FOR OPERATION 4.3 SURVEILLANCE REQUIREMENTS (c)

Out-of-sequence control rods in each distinct RWM group shall be selected and the annunciator of the selection errors verified.

(d)

An out-of-sequence control rod shall be withdrawn no more than three notches and the rod block function verified.

4.

The control rod pattern and sequence of withdrawal or insertion shall be verified to comply with Specification 3.3.B.4.

5.

Prior to control rod withdrawal for startup or during refueling, verification shall be made that at least two source range channels have an observed count rate of at least three counts per second.

4.

Control rod patterns and the sequence of withdrawal or insertion shall be established such that the rod drop accident limit of 280 cal/g is not exceeded.

5.

Control rods shall not be withdrawn for startup or refueling unless at least two source range channels have an observed count rate greater than or equal to three counts per second.

6.

One or more control rods inoperable for reasons other than those specified in 3.3.A, 3.3.C or 3.3.D.

---

NOTE:--------

RWM may be bypassed as allowed by LCO 3.3.B.3, if required, to allow insertion of inoperable control rods and continued operation.

(a) Fully insert inoperable control rod within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, AND (b) Disarm the associated CRD within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

7.

If the above specifications are not satisfied, an orderly shutdown shall be initiated and the reactor shall be in the HOT SHUTDOWN condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Amendment No.

4, 4&1, 2-1-4, 2-3-3, 244 84

VYNPS BASES:

3.3 & 4.3 (Cont'd)

2.

The control rod housing support restricts the outward movement of a control rod to less than 3 inches in the extremely remote event of a housing failure.

The amount of reactivity which could be added by this small amount of rod withdrawal, which is less than a normal single withdrawal increment, will not contribute to any damage of the primary coolant system.

The design basis is given in Subsection 3.5.2 of the

FSAR, and the design evaluation is given in Subsection 3.5.4.

This support is not required if the reactor coolant system is at atmospheric pressure since there would then be no driving force to rapidly eject a drive housing.

3.

In the course of performing normal startup and shutdown procedures, a

pre-specified sequence for the withdrawal or insertion of control rods is followed.

Control rod dropout accidents which might lead to significant core damage, cannot occur if this sequence of rod withdrawals or insertions is followed.

The Rod Worth Minimizer restricts withdrawals and insertions to those listed in the pre-specified sequence and provides an additional check that the reactor operator is following prescribed sequence.

Although beginning a reactor startup without having the RWM operable would entail unnecessary risk, continuing to withdraw rods if the RWM fails subsequently is acceptable if a second licensed operator verifies the withdrawal sequence.

Continuing the startup increases core power, reduces the rod worth and reduces the consequences of dropping any rod.

Withdrawal of rods for testing is permitted with the RWM inoperable, if the reactor is subcritical and all other rods are fully inserted.

Above 17% power, the RWM is not needed since even with a single error an operator cannot withdraw a rod with sufficient worth, which if dropped, would result in anything but minor consequences.

4.

Refer to the "General Electric Standard Application for Reactor Fuel (GESTAR II)," NEDE-24011-P-A, (the latest NRC-approved version will be listed in the COLR).

5.

The Source Range Monitor (SRM) system provides a scram function in noncoincident configuration.

It does provide the operator with a visual indication of neutron level.

The consequences of reactivity accidents are a function of the initial neutron flux.

The requirement of at least three counts per second assures that any transient, should it occur, begins at or above the initial value of 10-8 of rated power used in the analyses of transients from cold conditions.

One operable SRM channel is adequate to monitor the approach to criticality, therefore, two operable SRM's are specified for added conservatism.

6.

With one or more control rods inoperable for reasons other than those specified in 3.3.A, 3.3.C or 3.3.D, operation may continue, provided the control rods are fully inserted within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and disarmed (electrically or hydraulically) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Inserting a control rod ensures the shutdown and scram capabilities are not adversely affected.

The control rod is disarmed to prevent inadvertent withdrawal during subsequent operations.

The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves.

The control rods can be electrically disarmed by disconnecting power from all four directional control valve solenoids.

Required action 3.3.B.6 is modified by a note, which allows the RWM to be bypassed, if required, to allow insertion of the inoperable control rods and continued operation.

LCO 3.3.B.3 provides additional requirements when the RWM is bypassed to ensure compliance with the CRDA analysis.

7.

The action statement for TS 3.3.B.7 requires that the plant be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the required actions of TS 3.3.B.1 through 3.3.B.6 are not satisfied.

This ensures that all insertable control rods are inserted and places the reactor in a condition that does not require the active function (i.e.,

scram) of the control rods.

The allowed completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based upon operating experience to reach HOT SHUTDOWN from full power in an orderly manner and without challenging plant systems.

Amendment No.

2-5, 4--,

a-44-,

SV 99 !1-!,

BZY.g4, 2_L4 2-3-3 90