JAFP-13-0063, Application to Revise Technical Specifications to Adopt TSTF-535, Revise Shutdown Margin Definition to Address Advanced Fuel Designs

Application to Revise Technical Specifications to Adopt TSTF-535, Revise Shutdown Margin Definition to Address Advanced Fuel Designs

ML13171A008
Person / Time
Site:	FitzPatrick
Issue date:	06/07/2013
From:	Coyle L Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
JAFP-13-0063
Download: ML13171A008 (12)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-349-6024 Fax 315-349-6480 Lawrence M. Coyle Site Vice President - JAF JAFP-13-0063 June 7, 2013 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-535, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed amendment modifies the TS definition of "Shutdown Margin (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature that represents the most reactive state throughout the operating cycle. This change is needed to address new Boiling Water Reactor (BWR) fuel designs which may be more reactive at shutdown temperatures above 68°F. provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages.

Approval of the proposed amendment is requested by January 27, 2014, which will support JAFs continued operation until the end of cycle. Once approved, the amendment will be 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 State Official.

If you should have any questions regarding this submittal, please contact Mr. Chris M. Adner, Licensing Manager, at 315-349-6766.

JAFP-13-0063 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on June 18, 2013.

LC/CNjo Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Markup)

3. Revised Technical Specification Changes (Clean) cc:

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713 Resident Inspector's Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. Mohan Thadani, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Ms. Bridget Frymire New York State Department of Public Service 3 Empire State Plaza, 101h Floor Albany, NY 12223 Mr. Francis J. Murray Jr., President New York State Energy and Research Development Authority 17 Columbia Circle Albany, NY 12203-6399

JAFP-13-0063 Attachment 1 Description and Assessment (3 Pages)

JAFP-13-0063 Attachment 1 Description and Assessment

1. DESCRIPTION The proposed change revises the definition of Shutdown Margin (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature corresponding to the most reactive state throughout the operating cycle. This change is needed to address new Boiling Water Reactor (BWR) fuel designs which may be more reactive at shutdown temperatures above 68°F.

2. ASSESSEMENT 2.1 Applicability of Published Safety Evaluation Entergy Nuclear Operations, Inc. (Entergy) has reviewed the model safety evaluation dated February 19, 2013, as part of the Federal Register Notice of Availability. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-535. Entergy has concluded that the justifications presented in the TSTF-535 proposal and the model safety evaluation prepared by the NRC staff are applicable to the James A. FitzPatrick Nuclear Power Plant (JAF) and justify this amendment for the incorporation of the changes to the JAF Technical Specifications (TS).

2.2 Optional Changes and Variations The Traveler and model Safety Evaluation discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC). JAF was not licensed to the 10 CFR 50, Appendix A, GDC. However, with respect to the proposed change to the definition of SDM, the JAF Updated Final Safety Analysis Report (UFSAR) Section 16.6.2 and Table 16.6-3 describe conformance to the GDC 26 and GDC 27 criteria.

JAFs Reactor Protection and Reactivity Control Systems provide assurance that the reactor core can be made and held subcritical from normal operation and from normal anticipated operational transients, by at least two reactivity control systems and that malfunction of a reactivity control system will not result in unacceptable damage to the fuel, or disrupt the core to the point of preventing core standby cooling if needed.

The two systems, consisting of moveable control rods (UFSAR subsection 3.4) and recirculation flow control (UFSAR subsection 7.9) in conjunction with the standby liquid control system (UFSAR subsection 3.9), are provided to meet the intent of these criteria. Operational control of reactivity is provided by a combination:

Movable control rods and their control; Reactor coolant recirculation flow control; and Nuclear design (including the burnable poison Gadolinium) that assures that sufficient reactivity compensation is always available to make the reactor subcritical from its most reactive condition including compensation for positive and negative reactivity changes from nuclear coefficients, fuel depletion and fission products transients and buildup even with the most reactive control rod fully withdrawn.

Page 1 of 3

JAFP-13-0063 Attachment 1

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Considerations Entergy requests adoption of TSTF-535, Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs," which is an approved change to the Standard Technical Specifications (STS), into the JAF TS. The proposed amendment modifies the TS definition of "Shutdown Margin (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature that represents the most reactive state throughout the operating cycle.

Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises the definition of SDM. SDM is not an initiator to any accident previously evaluated. Accordingly, the proposed change to the definition of SDM has no effect on the probability of any accident previously evaluated. SDM is an assumption in the analysis of some previously evaluated accidents and inadequate SDM could lead to an increase in consequences for those accidents. However, the proposed change revises the SDM definition to ensure that the correct SDM is determined for all fuel types at all times during the fuel cycle. As a result, the proposed change does not adversely affect the consequences of any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change revises the definition of SDM. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operations. The change does not alter assumptions made in the safety analysis regarding SDM.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Page 2 of 3

JAFP-13-0063 Attachment 1 The proposed change revises the definition of SDM. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The proposed change ensures that the SDM assumed in determining safety limits, limiting safety system settings or limiting conditions for operation is correct for all BWR fuel types at all times during the fuel cycle.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed change 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.

3.2 Conclusions In conclusion, based on the considerations discussed above, (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 Commissions 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.

4. ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Page 3 of 3

JAFP-13-0063 Attachment 2 Proposed Technical Specification Changes (Markup)

Page FOL Page 3 TS Page 1.1-5

(4) ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools..

(5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 304, are hereby incorporated in the renewed operating license.

The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 1974; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989), 135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993),

190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994) and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, April 30, 1986, September 15, 1986 and September 10, 1992 subject to the following provision:

Amendment

Definitions 1.1 1.1 Definitions (continued)

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP)rate to the reactor coolant of 2536 MWt.

REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from when the monitored parameter exceeds its RPS TIME trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

SHUTDOWN MARGIN (SDM) SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is 68F, corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

(continued)

JAFNPP 1.1-5 Amendment

JAFP-13-0063 Attachment 3 Revised Technical Specification Pages (Clean)

Pages FOL Page 3 TS Page 1.1-5

(4) ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools..

(5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. , are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 1974; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989), 135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993),

190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994) and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, April 30, 1986, September 15, 1986 and September 10, 1992 subject to the following provision:

Amendment

Definitions 1.1 1.1 Definitions (continued)

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP)rate to the reactor coolant of 2536 MWt.

REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from when the monitored parameter exceeds its RPS TIME trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

SHUTDOWN MARGIN (SDM) SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is 68F, corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

(continued)

JAFNPP 1.1-5 Amendment