NL-16-1571, Supplemental Response Regarding Request to Adopt TSTF-222, Control Rod Scram Times

Supplemental Response Regarding Request to Adopt TSTF-222, Control Rod Scram Times

ML16239A309
Person / Time
Site:	Hatch
Issue date:	08/26/2016
From:	Wheat J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-16-1571
Download: ML16239A309 (10)

Text

Justin T. Wheat Southern Nuclear Nuclear Licensing Manager Operating Company, Inc.

A Southern Nuclear 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.5998 Fax 205.992.7601 August26,2016 Docket Nos.: 50-321 NL-16-1571 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Units 1 and 2 Supplem'ental Response Regarding Request to Adopt TSTF-222, Control Rod Scram Times Ladies and Gentlemen:

By letter dated October 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14288A226), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for the Hatch Nuclear Plant (HNP), Units 1 and 2, to adopt various previously approved Technical Specifications Task Force (TSTF) Travelers, including TSTF-222, Control Rod Scram Times. It was subsequently noticed that the HNP Technical Specification (TS) changes inserted the words "affected fuel cell" into Surveillance Requirement (SR) 3.1.4.4, whereas to be consistent with TSTF-222 the changes should have inserted the words "affected core cell". In addition, the TS Bases markups for SR 3.1.4.1 also stated fuel cell" instead of "core cell." provides the revised TS markups for HNP Unit 1 and Unit 2. The revised TS Bases Markups for SR 3.1.4.1 are also provided in Enclosure 1 for NRC information only. Enclosure 2 provides the corresponding revised TS clean pages. Please note that the justification for the proposed change provided in the October 10, 2014 SNC LAR, including the Significant Hazards Consideration, is unaffected by the revision provided in this letter.

U.S. Nuclear Regulatory Commission NL-16-1571 Page2 Mr. J. T. Wheat states he is Nuclear Licensing Manager of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted,

,' ..... j Nuclear Licensing Manager )

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JTW/RMJ d before me this&_ day of f+v "r *4 J- 12016.

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My commission expires:

Enclosures:

1. TSTF-222 Revised TS and TS Bases Marked-up Pages

2. TSTF-222 Revised TS Clean Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. -s. J. Adams, Vice President- Engineering Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch RType: CHA02.004 .

U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Supplemental Response Regarding Request to Adopt TSTF-222, Control Rod Scram Times Enclosure 1 TSTF-222 Revised TS and TS Bases Marked-up Pages

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS ITSTF-222 I

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NOTE-----

During single control rod scram time Surveillances, the control rod drive (CRD) pumps shall be isolated from the associated scram accumulator.

SURVEILLANCE FREQUENCY n.*

SR 3.1.4.1 Verify each control rod scram time is within the limits of Table 3.1.4-1 with reactor steam dome A;...*;;:* ~'T'n

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pressure~ 800 psig. mevemeAt ViithiA tfle reaeter preaatJre oessel Prior to exceeding 40% RTP after each reactor shutdown

~ 120 days SR 3.1.4.2 Verify, for a representative sample, each tested In accordance with control rod scram time is within the limits of the Surveillance Table 3.1.4-1 with reactor steam dome pressure Frequency Control

~ 800 psig. Program SR 3.1.4.3 Verify each affected control rod scram time is Prior to declaring within the limits of Table 3.1.4-1 with any reactor control rod steam dome pressure. OPERABLE after Prior to exceeding 40% RTP after fuel work on control rod movement within the affected core cell or CRD System that could affect scram time

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SR 3.1.4.4 Verify each affected control rod scram time is Prior to exceeding within the limits of Table 3.1.4-1 with reactor 40% RTP after steam dome pressure ~ 800 psig. work on control rod or CRD System that could affect scram time HATCH UNIT 1 3.1-10 Amendment No. m

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS ITSTF-222 I

- - - - - -- - - - - - - - - - - - - - - N O T E - - - - - - - - - - - - - - - - - - -

During single control rod scram time Surveillances, the control rod drive (CRD) pumps shall be isolated from the associated scram accumulator.

SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify each control rod scram time is within the Prier te exeeeding limits of Table 3.1.4-1 with reactor steam dome 4Q% R=i=P afteF ft:fel pressure 2: 800 psig. me'temeflt witl'liR tfle reeeter pressure vessel

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Prior to exceeding 40% RTP after each reactor shutdown 2: 120 days SR 3.1.4.2 Verify, for a representative sample, each tested In accordance with control rod scram time is within the limits of the Surveillance Table 3.1 .4-1 with reactor steam dome pressure Frequency Control 2:800 psig. Program SR 3.1.4.3 - Verify each affected control rod scram time is Prior to declaring within the limits of Table 3.1.4-1 with any reactor control rod steam dome pressure. OPERABLE after Prior to exceeding 40% RTP after fuel work on control rod movement within the affected core cell or CRD System that could affect

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scram time AND

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SR 3.1.4.4 Verify each affected control rod scram time is Prior to exceeding within the limits of Table 3.1.4-1 with reactor 40% RTP after steam dome pressure 2: 800 psig. work on control rod or CRD System that could affect scram time HATCH UNIT2 3.1-10 Amendment No. ~

Control Rod Scram Times B 3.1.4 ITSTF-222 BASES SURVEILLANCE SR 3.1.4.1 (continued)

REQUIREMENTS acceptable scram times for the transients analyzed in References 3 and4.

Maximum scram insertion times occur at a reactor steam dome 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 measured 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 that scram time testin ~ is ~erformed within a reasonable time following ~

I mo~ement withiR ~e ;!actor press1:1re ¥essel er after Ia shutdown

120 days or longer, control rods are reauired to be tested before exceeding 40% RTP. IIn the event fuel mo~ement is limited to selected core cells, it is U'le iAteAt of this SR that oAiy these GRDs

~- ' '-

.11. .ZL. .... L req1:1ired to be scram time tested. IThis 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 ork on control rods or the CRD System.

fuel movement within the SR 3.1.4.2 associated core cell and by 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 7.5% of the control rods in the sample tested are determined to be "slow". With more than 7.5% of the sample declared to be "slow" per the criteria in Table 3.1 .4-1, additional control rods are tested until this 7.5%

criterion (i.e., 7.5% 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 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 may have been previously tested in a sample. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

HATCH UNIT 1 B 3.1-22 REVISION~

Control Rod Scram Times B 3.1.4 jTSTF-222 BASES SURVEILLANCE SR 3.1.4.1 (continued)

REQUIREMENTS acceptable scram times for the transients analyzed in References 3 and4.

Maximum scram insertion times occur at a reactor steam dome pressure of approximately BOO 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 <:: BOO psig ensures that the measured 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 that scram time testin~ is ~erformed within a reasonable time following !firnB lmo't'emeflt 't'tithifl l=le :eaetor pressure vessel er afteij a shutdown

<:: 120 days or longer, control rods ere uired to b tes ed or exceed in 40% RTP. IFI the e'f'eAt fuel mo'f'emeflt is limited to

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• 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 work on control rods or the CRD System.

fuel movement within the SR 3.1.4.2 associated core cell and by 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 7.5% of the control rods in the sample tested are determined to be "slow". With more than 7.5% of the sample declared to be "slow" per the criteria in Table 3.1.4-1, additional control rods are tested until this 7.5%

criterion (i.e., 7.5% 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 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 may have been previously tested in a sample. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

HATCH UNIT 2 B 3.1-22 REVISION I!U

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Supplemental Response Regarding Request to Adopt TSTF-222, Control Rod Scram Times Enclosure 2 TSTF-222 Revised TS Clean Pages

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS

---

NOTE-----------------------

During single control rod scram time Surveillances, the control rod drive (CRD) pumps shall be isolated from the associated scram accumulator.

SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify each control rod scram time is within the Prior to exceeding limits of Table 3.1.4-1 with reactor steam dome 40% RTP after each pressure ;:: 800 psig. reactor shutdown

120 days SR 3.1.4.2 Verify, for a representative sample, each tested In accordance with control rod scram time is within the limits of the Surveillance Table 3.1.4-1 with reactor steam dome pressure Frequency Control

800 psig. Program SR 3.1.4.3 Verify each affected control rod scram time is Prior to declaring within the limits of Table 3.1.4-1 with any reactor control rod steam dome pressure. 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 is Prior to exceeding within the limits of Table 3.1.4-1 with reactor 40% RTP after fuel steam dome pressure ;

: 800 psig. movement within the affected core cell Prior to exceeding 40% RTP after work on control rod or CRD System that could affect scram time HATCH UNIT 1 3.1-10 Amendment No.

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS

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NOTE--------------------

During single control rod scram time Surveillances, the control rod drive (CRD) pumps shall be isolated from the associated scram accumulator.

SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify each control rod scram time is within the Prior to exceeding limits of Table 3.1.4-1 with reactor steam dome 40% RTP after each pressure 2: 800 psig. reactor shutdown 2: 120 days SR 3.1.4.2 Verify, for a representative sample, each tested In accordance with control rod scram time is within the limits of the Surveillance Table 3.1.4-1 with reactor steam dome pressure Frequency Control 2:800 psig. Program SR 3.1.4.3 Verify each affected control rod scram time is Prior to declaring within the limits of Table 3.1.4-1 with any reactor control rod steam dome pressure. 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 is Prior to exceeding within the limits of Table 3.1.4-1 with reactor 40% RTP after fuel steam dome pressure 2: BOO psig. movement within the affected core cell Prior to exceeding 40% RTP after work on control rod or CRD System that could affect scram time HATCH UNIT2 3.1-10 Amendment No.