ML130090298

E-mail from J. Kim to J. Devincentis Request for Additional Information - Rod Worth Minimizer Bypass Allowance Amendment

ML130090298
Person / Time
Site:	Vermont Yankee
Issue date:	04/10/2012
From:	James Kim Plant Licensing Branch 1
To:	Devincentis J Entergy Nuclear Vermont Yankee
Guzman R, NRR/DORL 415-1030
References
Download: ML130090298 (3)

Text

From: Guzman, Richard To: Kim, James

Subject:

RE: Draft RAI-Rod Worth Minimizer Bypass Allowance Amendment Date: Tuesday, April 10, 2012 3:55:20 PM Thanks, Jim.

Rich From: Kim, James Sent: Tuesday, April 10, 2012 1:58 PM To: Devincentis, James M Cc: Couture III, Philip; Guzman, Richard

Subject:

Draft RAI-Rod Worth Minimizer Bypass Allowance Amendment Jim D.

Below is the draft RAI from the tech staff concerning the Rod Worth Minimizer amendment request. Please let Rich Guzman know if you want to have a phone call to discuss the RAI questions.

Thanks Jim REQUEST FOR ADDITIONAL INFORMATION In letter dated February 1, 2012, Entergy Nuclear Operations, Inc. (the licensee) proposed changes to the Technical Specifications (TS) for Vermont Yankee Nuclear Power Station (VY). The proposed changes would revise VY TS 3.3.B.3 allowances for bypassing the Rod Worth Minimizer. VY TS 3.3.B.3 currently states:

3. While the reactor is below 17% power, the Rod Worth Minimizer (RWM) shall be operating while moving control rods except that:

(a) If after withdrawal of at least 12 control rods during a startup, the RWM fails, the startup may continue provided a second licensed operator verifies that the operator at the reactor console is following the control rod program; or (b) If all rods, except those that cannot be moved with control rod drive pressure, are fully inserted, no more than two rods may be moved.

Specifically, the proposed changes would revise VY TS 3.3.B.3 to:

3. While the reactor is below 17% power, the Rod Worth Minimizer (RWM) shall be operable while moving control rods except that:

(a) If the RWM is inoperable during a reactor startup.

1. Immediately suspend control rod movement except by scram.

OR

2.1.a Immediately verify 12 rods withdrawn, OR 2.1.b Immediately verify by administrative measures that startup with the RWM inoperable has not been performed in the last 12 months.

AND 2.2. During control rod movement, verify movement of control rods is in compliance with banked position withdrawal sequence (BPWS) by a second licensed operator or other qualified member of the technical staff.

(b) If the RWM is inoperable during a reactor shutdown, during control rod movement, verify movement of control rods is in compliance with BPWS by a second licensed operator or other qualified member of the technical staff.

Basis for the Request Entergy Nuclear Operations, Inc., stated in its application that the proposed TS change would revise TS 3.3.B.3 allowances for bypassing the Rod Worth Minimizer (RWM) consistent with the allowances provided in NUREG-1433 Volume 1, Revision 3.0, Standard Technical Specifications [STS] General Electric Plants, BWR/4. In addition, Entergy Nuclear Operations, Inc., stated, This proposed change is consistent with the Standard Technical Specifications (STS) as modified by TSTF-464-T. TSTF-464-T addressed a conflict between the STS and the STS Bases and recommended use of the term in the last 12 months versus in the last calendar year.

There is a conflict between the STS and the STS Bases. The STS Bases are in error to the STS contained in NUREG-1433, Revision 3.0. TSTF-464-T was not submitted to the NRC for review and therefore, TSTF-464-T has not been approved by the NRC.

NUREG-1433 volume 1, revision 3.0, TS 3.3.2.1, Control Rod Block Instrumentation, Condition C is entered when the Rod worth minimize (RWM) is inoperable during reactor startup and its associated required actions require:

C.1 Immediately suspend control rod movement except by scram.

OR C.2.1.1 Immediately verify 12 rods withdrawn.

OR C.2.1.2 Immediately verify by administrative methods that startup with RWM inoperable has not been performed in the last calendar year.

AND C.2.2 During control rod movement, verify movement of control rods is in compliance with banked position withdrawal sequence (BPWS) by a second licensed operator or other qualified member of the technical staff.

Required Action C.2.1.2 specifically uses the phrase, in the last calendar year. Entergy Nuclear Operations, Inc., is proposing to use the phrase, in the last 12 months. The proposed phrase, in the last 12 months is non-conservative and not consistent with NUREG-1433, volume 1, revision 3.0. The NUREG-1433 phrase, in the last calendar year, will not allow a plant to perform a startup with RWM inoperable in the current calendar year i.e., 2012, if the plant had performed a startup with RWM inoperable in the last calendar year, i.e., 2011.

Request for Additional Information #1 Entergy Nuclear Operations, Inc. proposed to revise TS 3.3.B.3 allowances for bypassing the RWM consistent with the allowances provided in NUREG-1433, volume 1, revision 3.0. However, the proposed required action 2.1.b in TS 3.3.B.is not consistent with NUREG-1433, 1, Revision 3.0 and is also non-conservative.

Provide a technical evaluation that addresses the non-conservative phrase, in the last 12 months in proposed required action 2.1.B or provide technical specifications that are consistent with NUREG-1433, volume 1, revision 3.0.

Regulatory Analysis Basis 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit states:

Whenever a holder of a license, including a construction permit and operating license under this part, and an early site permit, combined license, and manufacturing license under part 52 of this chapter, desires to amend the license or permit, application for an amendment must be filed with the Commission, as specified in §§ 50.4 or 52.3 of this chapter, as applicable, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.