ML20118A372
| ML20118A372 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/25/1992 |
| From: | Starkey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20118A373 | List: |
| References | |
| NLS-92-233, NUDOCS 9209020044 | |
| Download: ML20118A372 (15) | |
Text
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C9&L I
Carolina Power & Light Company P O Eksa 1551
- Haioift tdG i7602 bbi 2 6 bd2 SERIAL: NLS-92 233 10 CFR 50,90 n a stu wtv.sa iSC 91TSB16 vo nwoem Natent Seewes DepawM United States Muclear Regulatory Comnission ATTENTION:
Document Control Desk Washington, DC 205;5 BRUNSWCR STEAM ELECTRIC PIANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50 325 6 $0 324/ LICENSE NOS DPR-71 & DPR 62 REQUEST FOR LICENSE AMENDMENT CONTROL ROD SCRAM TIME TESTINC Centlemen:
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP),
Units 1 and 2.
The proposed change increases the acceptable limits for control 194 average scram insertion times from 0.040 to 0.049 seconds for each of the rod positions listed in Technical Specifications 3.1.3.3 and 3.1.3.4.
In addition, the proposed change revises the values of mu, sigma, and r4 specified in Technical Specification 3.2.2.2 that are used to determino the cycle overage 20 percent scram time ( r.y.). provides a detailed description of the proposed changes and the basis for the changes. details, in accordat.a with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical exclusion set forth_in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment needs to be_ prepared in connection with Isr.uance of the amendment. provides the marked-up Technical Specification pages for Unit 1. provides the marked up Technical Specification pages for Unit 2.
CP&L is providing, in accordance with 30 CFR 50.91(b), the State of North Carolina with a copy of the proposed license amendment.
In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CF6L requests that the proposed
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Document Control Desk NLS 92 233 / PAge. 2 amendments, once approved by the NRC, be issued with an effective date to be no later than 60 days from the issuance of the amendment.
1 Please refer any questions regarding this submittal to Mr. K. A. liarris at (919) 546 3077.
Yours very truly,
$A n-R. B. Starkey, Jr.
KAll/kah (seramtsc.th)
Enc M ures:
.1.
. Basis for Change Request 2,
10 CFR 50.92 Evaluation 3.
Envirotunental Considerations 4.
Marked up Technien1 Specification Pages. Unit 1 l
.5.
Marked up Technical Specification Pages Unit 2 R. B. Starkey, Jr., having' been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his informati,n, knowledge and belief, and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light
- Company,
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i ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC ptANT, UNITS 1 AND 2 NRC DOCKET NOS. 50 025 6 50 324 OPERATING LICENSE NOS. DPR-71 6 DPR-62 REQUEST FOR LICENSE AMENDMENT CONTROL ROD SCRAM TIME TESTING l
t BASIS FOR CHANGE RE00EST s
Encktround:
The Rod Worth Minimizer-(RVM) hardware was upgraded to a NUMAC based system in 1989 for Unit 1 and in 1988 for Unit 2.
The capabilities of the-upgraded RVM system allow more detailed and complete insertion times to be recorded,
. including the timing of both the pickup and the dropout of individual reed or: aches during each automatic scram and during individual control rod scram time testing required by Technical Specification 4.1.3,2.
The current values of the scram insertion times of Technical Specification 3.1.3.3 are based on the 67B scram insertion time curve.
The capability to directly measure the dropout times for each individual reed switch makes it unnecessary to interpret tho 67B scram insertion time-curve to obtain scram insertion times.
The proposed values for Technical Specification '3.1.3.3 are the 67B scram curve percent insertion values adjusted to a nearby notch position and the middle'of the reed switch.
These notch position insertion times are reported to the nearest millisecond, consistent with the edit of the
.RWM.NUMAC. System.
To avoid possible confusion and to maintain consistency between the different Technical Specifications addressing scram insertion times, the proposed change revises the values of mu, sigma, and r4 in Specification 3.2.2.2 to values appropriate for' dropout of.the reed switch and the proposed Technical Specification 3.1.3.3 notch 36 scram insertion time.
l Eronosed Chance:
k The proposed change increases the acceptable limits for control rod average
~
scram insertion times from 0.040 to 0.049 seconds for each of the rod positions listed in Technical Specifications 3.1,3.3 and 3.1.3.a.
In addition;Lthe proposed change revises the values of mu, sigma, and r4 specified-in Technical Specification 3.2.2.2 that are useo to determine the cyclo average 20% scram time.(ro,),
i hasis:
Technical Specifications:3.1.3.3 and 3.1.3.4 ensure that control rod insertion times are consistent with those used in the accident analysis.
Specifically.
control rod scram insertion times are listed in the Technical Specifications El 1 p
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r to ensure that actual control rod drive parformance during a plant transient
.f is bounded by the reactivity assumed in the safety analysis to be inserted by a reactor scram.
The control rod system is analyzad to bring the reactor suberttical at a rate fast enough to prevent the Minimum Critical power Ratio (MCPR) from becoming less than the Safety Limit MCPR of Technical Specification 2.1.2 during the limiting power transient analyzed in f
Section 14.3 of the Final Safety Analysis Report (Section 15.2 of the Updated Final Safety Anslysis Report).
This analysis shows that the negative reactivity rates resulting from the scram with the average response of all drives, as-stated in Technical Specifications 3.1.3.3 and 3.1.3.4, provide the required protection and that MCPR remains greater than the Safety Limit MCPR
- of Technical Specification 2.1.2.
Technical Specification 3.1.3.3 provides requirements for the average scram insertion time of all OPERABLE control rods.
The Technical Specification 3.1.3.3 insertion times are stipulated for four insertion-positions. Technical Specification 3.1.3.4 provides requirements for the average scram insertion time of each group af four control rods (arranged in a two by-two array).
The Technical Specification 3.1.3.4 insertion times are airo stipulated for four-insertion positions.
In the recent and current safety analyses performed each cycle, the scram
- reactivity function assumed is the 67B scram insertion timo curve.
The 67B scram insertion time curve specifies the amoun' of scram reactivity in terms of percent insertion ~ as a function of time.
Control rod scram insertion times can be measured from the de energization of the scram solenoid to either the pickup or dropout of,the control rod notch position' reed switch.
For simplicity in demonstrating compliance to the 67B scram curve, the 67B curve information is converted from rercent insertion versus time to notch position versus time.
?The 67B scram curve times represent the time at which the control rod reaches the indicated percent insertion.
When a control rod-scrams from the fully
- withdrawn position, the ~" full out" and notch 40 reed switches first drop out
- as the control' rod starts its insertion motion. When the initial reed switch dropout occurs, the control rod has already inserted a distance that is on the order of the length of the reed switch (approximately one inch).
For purposes of adjusting the 67B scram curve times from percent insertion to notch position dropout, the control rod is taken to be inserted approximately
- one half this distance (i.e., approximately 1/2 inch).
To convert [from percent insertion versus time to notch position dropout versus time, a notch position near the specific 67B percent inserted value is selected, fThe percent insertion of this notch position is determined by linear interpolation and increased by the insertion needed to achieve dropout of the reed switch (approximately half the length of the reed switch).
The time required forJthe equivalent notch position dropout insertion percentage is then calculated by linear interpolation between adjacent 67B curve percent scram insertion times.
- The scram insertion times as a function of notch position from the de-energization_of the scram solenoid to dropout of the control rod position reed El-2 i
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switch for the_three fastest control rods in each group of four control rods i
and for the average of all control rods are documented in Reference 1.
These values are presented in Table 1 below.
Both two and three significant figures after the decimal point are provided.
Truncation of the third digit to the right of the decimc1 point is conservative when reporting only two significant figures after the decimal point since this requires the control rods be insetted faster.
i
-t Table 1:
Scram Insertion Times frors Reference 1 (Attachment 1)
Notch 3 of 4 3 of 4 Average Average position time
-time time time (sec)
(sec)
(sec)
(sec) 46 0.37 0.379 0.35 0.358 36 1.16 1.162 1.09 1.096 t
26 1.97 1.971
' 86 1.860 06 3.62 3.624 3.41 3.419 The RUM hardware.was upgraded to a NUMAC based system in 1989 for Unit 1 and in 1988 for Unit 2.
The capabilities'of the upgraded RWM system allow more detailed and complete insertion times to be recorded, including the timing of both the pickup and the dropout of individual reed switches during each automatic scram and during individual control rod scram time testing required
'by Technical Specification 4.1.3.2.
The existing requirements of Technical Specifications 3.1-3.3 and-3.1.3.4 are-the values of_ Table 1 above, reported to two significant figures-after the decimal point reduced by 0.04 seconds to' conservatively bound the delay
.between pickup and dropout. Actual recorded data from the upgraded RWM system indicate that the average delay between reed switch pickup and dropout is approximately 0.02 seconds.
Those measurements confira-the conservatism of the 10.04'second value that was previously assumed _ in adjusting the 67B scram curve from reed switch dropout times to reed switch pickup times, Since there.now exists the capability to directly measure _the dropout times
-for each individual reed switch using the NUMAC based RRM system, it is no longer necessary to' interpret tb3 67B scram curve for pickup times.
Baseo on the direct measurement capability, the proposed values for Technical Specifications 3.1.3.3 and 3.1,3.4 are the 67B scram curve percent insertion values adjusted to a nearby notch position and for the physical dimensions of
- the reed switch.
The notch position insertion times currently cited in Technical Specifications 3.1.3.3 and 3.1.3.4_are reported to_the nearest hundredths of a second.
The proposed notch position insertion times are El 3 l
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s reported to the_ neare:.t inillisecond, consistent with the output fortnat of the RkH systern.
The values of ruu and sigma referenced in Technical specification 3,2,2.2 are used to determine the scra:n tirne requirement (ts) for use of reduced thermal litnits provided by the ODYN Option B methodology. When the cycle average insertion time (r,y.) is less than r, the ODYN Option B thermal 11: nits are e
applicable. When the value of r,y, is greater than the value of r for ODYN Option B (f s) but less than the value of r for ODYN Option A (tau ), the x
therrnal liinits are determined by linear interpolation between the ODYN Option A and B therinal-limits. This process is-described in Technical y
Specification 3.2.2.2..
Tre current values of mu, sigina, and r4 in Technical Specification 3.2.2.2 are i
appropriate when the cycle average insertion time (r y.) is ineasured from de energination of the scrain pilot valve solenoid to reed switch pickup at the notch 36 position.
The proposed values of au (0.830) and sigma _(0.019)-are approFriate when the insertion time is incasured from de-energization of the 4
scram pilot valve solenoid to dropout of the notch 36 position reed switch notch (see Table 3. Reference 1),
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Letter, L. M. Quintana to B. A. Morgen, " Dropout Basis Scram Insertion Times Requirernents," December 9, 1991, 114Q:91 341, File NF 402.1004 I
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ATTACHMENT 1 TO ENClDSURE 1 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 6 50 324 OPERATING LICENSE NOS. DPR.71 & DPR 62 REQUEST I'OR LICENSE AMENDMENT CONTROL ROD SCRAM TIME TESTING REFERENCE 1 El-5 1,
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- . ~. me.e a a wn NF 4MIM' n.it et,s. its cc: S. J. Ganthner December 9, 1991 RECEIVED R. G. Matthews LMQ: 91 341
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DEC 9 1991 i
BRUCE MORGEN !
Mr. B. A. Morgen Project Engineer Fuel Projects Carolina Power & Light company P. O. Box 1551 Raleigh, NC 27602
Subject:
Dropout Basis Scram Insertion Times Requirements
Reference:
1)
Letter, G. R. Hull to J. D. Martin, " Brunswick 1/2 Scram Insertion Times? December 14, 1982.
2)
Letter, L. M. Quintana to J. D. Martin, " Control Rod Scram Insertion Times 67B Curve? October 31, 1983.
3)
Letter, L. M. Quintana to B. A. Morgen, "Additionu Information for Application of GEMIN1 Methods?
April 14, 1987, 4)
Letter, L. M. Quintana to B. A. Morgen, " Technical Specificatiens for Three of Four Control Blades?
October 9, 1991.
Dear Bruce:
Per CP&L's request, this letter provides documentation supporting a pro-posed technical specifications (T/S) change to the control blade scram in-sertion times required for (1) tae average of all operable control blades, (2) the average of the three fastest in every two by two group of blades, and (3) the GEMINI methods ODYN Option B mean (p), standard deviation (o),
and 20% insertion average time (rA) values from a pickup of the reer*
switch basis to a dropout of the reed switch basis.
Background
Reference 1 documented the 67B curvo scrn time requirements on a T/S
- format, i.e., based on certain notch positions and measurable occurrences (pickup of reed switch).
Reference 2 provided background for the 675 curve and indicated that the notch position versus time T/S values <ould This.s a be _ohtained by linear interpolation of the 67B curve inputs.
conservative, simplified approach which does not take credit for the physical characteristics of the reed switches,
- t. more detailed approach l
to calculate the dropout T/S values is discussed later.
Reference 2 also
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2-December 9 1991 Mr. B. A. Morgen documented the conservative application of a 0.040 second difference between pickup and dropout of the reed switch which was used to support the currently existing Brunswick 1 and 2 T/S requirements.
Reference 3 provided an update to the y and a T/S values to support the change f rom the earlier GENESIS methodology to the current GEMINI methods.
Table 1 of Attachment 2 to this letter provided the current pickup basic Brunswick 1 and 2 T/S values for u and a.
The Brunswick 1 and 2 T/S value for r is e rrectly based on the corresponding Brunswick core average A
scram time for notch 36, 1.05 seconds for pickup of the reed switch.
(The values for r in Reference 3 while conservative, should not be useo in g
favor of the core average scram times described herein.)
CP&L recently requested the dropout basis best three out of four scram time requirements.
These were provided via Reference 4 and are provided j
again herein.
Recommended Dropout Basis Scram Times and Option B Values j
i The attached tables contain the 67B scram time requirements as a function of both insertion fraccion and dropout basis notch position.
The values
-for notch positions are consistent with the design specifications for the i
control rod drive system and have been provided to three decimal places for your information.
If two decimal place values are desired, the last digit should be conservatively dropped.
The notch position times are
- based on detection of the dropout of the applicable reed switch (switch opening).
The dropout insertion fractions are-asaumed to be 0.34% beyond the nominal notch position to account for the physical characteristics of the reed switches.
The CEMINI methods ODYN Option B y and a for dropout are shown and are the same as those provided in_ Reference 3.
The r value-shown in the attached tablo should be used in lieu of the value inkefer-ence 3.
If there are any -further questions, please do not hesitate to call us, Very truly yours, 4
am --
Louis M. Quintana L
Fuel Project Manager 2,
i Brunsw!p 162 e
L (408) i:S.2026 l:
1mq Attachment t
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3,.Y t Tr' ale 1 67B Scram T ma Aequirements Average :f the Average Scrarn Fastes; 3 of Insertior. Tige Each 2x2 Argay
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'5.00 0.375 0.398 20.00 0.900 0.954 e-50.00 2.000 24 90.00 3.500
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Table 2 Technical Specification Renuirements AvtragJ of the 8
Average Scram Fr.n. :t. 3 of Drornut of Insertior Tige Es t U2 Argay E :,e W i, b (seconds)
(seconds) 15 0.35f4 0.379 36 1.096 1.162 26 1.860 1.971 06 3.419 3.624 Il Table - 3 GEHINI ODYN Option B Requirements Dropout of 7
y a
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'4 Reed Switch (secBnds)
(seconds)
(setands) 36 1.096" 0.830 0.C;9 Times based on deenergization of the scram pilot valve slenoids as s
time zero.
- % From Table 2.
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4 ZNCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDMENT CONTROL ROD SCRAM TIME TESTING 10 CFR 50.92 EVA1.UATION The Commission has provided stanaards in 10 CFR 50.92(c) determining s.
whether a significant hazards consideration exists.
A prorrsed amendment to an opetiting license for a facility involves no significant hazards consideration if 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 dif ferent kind of accident from cny a cident previously evaluated, or (3) involve a significant reduction in a margin of safety.
Pursuant to 10 CFR 50.91(a)(1), Carolina Power & Light Company has reviewed this proposed license amendment r(quest and dotarmined that its adoption.muld not g
involve a significant hazards consideration. The bases for this determination jg.
are as follows:
. Proposed Chanha:
The proposed change increases the acceptable limits for control rod average scram insertion times from 0.040 to 0.049 seconds for each of the rod posi,lons listed in Technical Specifications 3.1.3.3 and 3.1.3.4.
In addition, the proposed change revises the values of mu, sigma, and e x specified in Technical Specification 3.2.2.2 that are used to determine the cycle-average 20 percent scram time (1,y. ).
Epsis:
The change does not involve a significant hazards consideration for the following rer wns:
1.
The proposed change does not involve a significant increase in the probability of an accident previously evaluated. The values of mu, sigma, and ri in Technical Specificatinn 3.2.2.2 do.ot affect any physical system or equipment which wouid change the probability of an accident. The proposed change to Technical Specifications 3.1.3.3 and 3.1.3.4 to increase the control rod average insertion times will not cause unplannet initiation of the control rod system, will not impede the initiation of the control rod system, and will not affect the probability of a control red drop accident.- Therefore, the proposed change does not result in a sir ificant increar,e in the probability of an accident previously evaluatcJ.
E2-1
. g 9x The. proposed change does not involve a significant increase in the
. contequences of anf accident previously evaluated. Technical
-Specifications 3.1_.3.3 and 3.1.3.4 ensure that control rod insertion times are consistent _ sich those used in the accident analysir.
Specifically,Jcontr.o1 rod scram insertion times are listed in the Technical-Specifications to ensure that. actual control rod drive performence during:a plant transient is bounded by the reactivity assumed in the safety analysis to be inserted by a reactor scram.
!a control rod system is analyzed to bring the reactor suberitical at a rate-fatt enough to prevent the Minimum Critical Power Ratio (MCPR) from becoming less than the Safety Limi. MCPR of Techt 11 Speciiication 2.1.~ 2 during the limiting power tra, int analyzed in Section 15.2_of the Up_ dated Final Safety Analysis keport.
The proposed change will define the scram insertion time from de-energization of.the-scr:.i solenoid to dropout of the control rod-position reed switch instead of from de-energization of the scram solenoid to pickup of1the control rod position reediswitch. The proposed values of mu,: sigma, and 3 will maintain fuelLthereal 'imite equivalent to the existing fuel 4thermal-limits nnd ensure that the Safety Limit MCPR stated in Technical Specification 2.1.2-is not exceeded.
Consequently, fuel failure assumptions previously used in analyses will not be exceeded, thereby ensuring the consequences of previously evaluated accidents and operational transients will not be significantly increased.
21 The proposed amendment does_not create the possibility of a new or
- different kind of accident from any accident previously evaluated.
The proposed changes.to Technical Specifications 3.1.3.3 andL3.1.3.4 to increase the. control rod average insertion times and the proposed changes to the values of mu, sigma, a..d r4 in. Tech.sical Specification 3.2.2.2 do not al cer ~oc change the manner in whicc the contrcl r 7d system performa its safe:y function. Also, the proposed changes will not cause unplanned _ initiation of the control rod system. nor-will the proposed changes impede the initiation of the control rod system.
No new or different oce of plant operation will be created as a result of the. proposed changes; therefore, no new or different kinds of accident than that previously_ evaluated vill be-created.
3.
LThe proposed _ change'does not involve a significant reduction in the margin-of safety. As discussedsin Item 1 above, Technical Specifications 3.1.3.3 and 3.1.3.4 ensure dbat control rod insertien times tre consistent with those used in the accident analysis.
Specifically, control rod scram insertion times are listed in the
-Technica1'Spacifications to ensure that actual control rod drive
. performance during a plant transient is bounded by the reactivity assumed in.the: safety analysis to be inserted by a reactor scram.
The control rod system is analyzed to bring'the-reactor suberitical at a i
rate fast enough to prevent the MCPR from becoming less than the Safety
- Limit MCPR-of Technical' Specification 2.1.2 during the limiting power transient analyzed in Section 15,2 of the Updated Final Safety Analysis Report. The_ proposed change will define the scram-insertion time frota de-energization of the scram solencid to dropout of the' control rod position. reed switch instead of from de-enargization of the scram E2-2 l
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~ -j solenoid to pickup of the control rod position reed switch.
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_ preposed valties of.mu sigma, 'and ri vill maintain fuel thermal limits -
-equivalent to:the existing fuel = thermal limits and ensure that the
. Safety Limit MCPR stated in Technical. Specification 2.1.2 is not jexceeded.
By ensuring that'the Safety Limit MCPR is not exceeded, fuel failure assumptions previously used in the safety analysis will not be exceeded; therefore, the margin of safety will not be significantly re duced.-
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9 ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR+71 6 DPR-62 REQUEST FOR LICENSE AMENDMENT CONTROL ROD SCRAM TIME TESTING ENVIRONMENTAL CONSIDERATIOM 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facilit - in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (3) result in an increase in indi'ridual or umulative occupational radiation exposure.
Carolina power & Light Company has reviewed this _aquest and catermined that the proposed amendment meets the eligibility criteria for cater;3rical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows.
Proposed Chance:
The proposed change increases the acceptable limit for control rod average scram insertion times from 0.040 to 0.049 seconds for each of the rod positions listed in Technical Specifications 3.1.3.3 and 3.1.3.4.
In addition, the proposed change revises the values of mu, sigma, and ri specified in Technical Specification 3.2.2.2 that are used to determine the cycle average 20 percent scram time (ry.).
Basin; The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
1.
As demonstrated in Enclo.4ure 2, the proposed amendment does not involve a significant hazards consideration.
2.
The proposed amendment does not result in a signifi ant change in the types or significant increase in the amounts of any affluents that may be released offsite.
Technical Specifications 3.1.3 3 and 3.1.3.4 ensure that control rod insertion times are consistent with those used in the accident analysis.
Spe cifica'. 7, control rod scram insertion times are listed in the Technical Specifications to ensure that actual control rod drive performance during a plant transient is bounded Ly the E3-1
4
+
reactivity assumed in the safety analyn to be inserted by a reactor scram.
The control rod system is analyzs.: to bring the reactor suberittaal at a rate fast enough to prevent the MCPR from becoming less than the Safety Limit MCPR of Technical Specification 2.1,2.
The proposed values of mu, sigma, and r, will maintain fuel thermal limits equivalent to the existing fuel thermel limits and ensure that the Safety Limit MCPR is not exceeded.
By ensuring that the Safety Limit MCPR is not exceeded, fuel failure assumptions previously used in the safety analysis will not be exceeded.
This will ensure the radiological source term used in the accident malysis remains bounded by that previously evaluated. As such, t.he proposed change cannot affect the types or amounts of any effluents that may be released offsite, 3.
The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure.
The proposed change will not alter the normal background radiattor; levels within the plant work areas. Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.
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