JAFP-24-0047, License Amendment Request – Temporary Addition to TS 3.3.2.1 Condition C, Control Rod Block Instrumentation to Support Upgrade to Rod Worth Minimizer Software
| ML24269A132 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/25/2024 |
| From: | Para W Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| JAFP-24-0047 | |
| Download: ML24269A132 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.constellation.com
JAFP-24- 0047
September 25, 2024
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DRP-59 NRC Docket No. 50-333
Subject:
License Amendment Request - Temporary Addition to TS 3.3.2.1 Condition C, "Control Rod Block Instrumentation" to Support Upgrade to Rod Worth Minimizer Software
Reference:
Letter from A. Sterio (James A. FitzPatrick) to NRC Document Control Desk, Request for Enforcement Discretion for Technical Specification (TS) 3.3.2.1 Control Rod Block Instrumentation, dated September 24, 2024 (ML24269A019)
Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF). The proposed amendment would temporarily revise Technical Specifications (TS) 3.3.2.1, "Control Rod Block Instrumentation, " Condition C.
At 22:54 on September 17, 2024, JAF entered Condition C of TS 3.3.2.1 for an inoperable Rod Worth Minimizer (RWM). Condition C restricts plant startup to once per calendar year without restoring the RWM system to operable. JAF conducted a plant startup from a planned refueling outage with the RWM inoperable on September 17, 2024. On September 23, 2024, at 07:20 JAF experienced an automatic SCRAM as a result of a main turbine trip due to an automatic trip of the generator output breakers (ENS #57333). The Nuclear Regulatory Commission (NRC) granted verbal approval of a Notice of Enforcement Discretion (NOED) to allow JAF to conduct plant startup on September 24, 2024, without having an operable RWM. CEG submitted the written NOED request to the NRC on September 25, 2024 (Reference).
This proposed amendment requests a temporary change to TS 3.3.2.1 Condition C for the operability of the RWM during reactor startup. The change adds a footnote to TS 3.3.2.1 Condition C which permits reactor startup with the RWM inoperable while the compensatory measure described in the, Section 3.5 to this letter is implemented. This allowance expires on December 31, 2024. This will provide time for the site to perform RWM software enhancements and adequately resolve the current RWM software issue. This proposed amendment was discussed verbally with the NRC on September 24, 2024.
provides an evaluation of the proposed changes, including an analysis of the no significant hazards consideration. Attachment 2 provides a markup of the TS.
U.S. Nuclear Regulatory Commission September 25, 2024 Page 2
The proposed changes have been reviewed by the JAF Plant Operations Review Committee in accordance with the requirements of the CEG Quality Assurance Program.
CEG is requesting approval of the proposed amendment on an expedited basis. Once approved, the amendment shall be implemented within 3 business days.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),
CEG is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.
There are no regulatory commitments contained in this submittal.
If you have any questions or require additional information, please contact Ronnie Reynolds at 267-533-5 698.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 25th day of September 2024.
Respectfully,
Wendi Para Sr. Manager - Licensing Constellation Energy Generation, LLC
Attachments: 1. Evaluation of Proposed Change
- 2. Proposed Technical Specifications Markup
cc: NRC Region I, Regional Administrator NRC Senior Resident Inspector, JAF NRC Project Manager, JAF A. L. Peterson, NYSERDA
Nuclear Regulatory Commission September 25, 2024 Page 3
bcc: Sr. Vice President, Mid-Atlantic Operations w/out attachments Sr. Vice President, Governance and Oversight "
Sr. Vice President, Engineering and Technical Services "
Site Vice President - JAF "
Plant Manager - JAF "
Director, Site Operations - JAF "
Director, Site Engineering - JAF "
Director, Organizational Performance and Regulatory - JAF "
Director, Licensing w/ attachments Sr. Manager, Licensing "
Licensing Engineer "
Regulatory Assurance Manager "
Commitment Tracking Coordinator "
Records Management "
ATTACHMENT 1
Evaluation of Proposed Changes
James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50- 333
Subject:
License Amendment Request - Temporary Addition to TS 3.3.2.1 Condition C, "Control Rod Block Instrumentation" to Support Upgrade to Rod Worth Minimizer Software
1.0
SUMMARY
DESCRIPTION
2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria
4.2 Precedent
4.3 No Significant Hazards Consideration
4.4 Conclusions
5.0 ENVIRONMENTAL CONSIDERATION
Evaluation of Proposed Changes Page 1 of 9
1.0
SUMMARY
DESCRIPTION
Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF). The proposed amendment would temporarily revise Technical Specifications (TS) 3.3.2.1, "Control Rod Block Instrumentation," Condition C.
At 22:54 on September 17, 2024, JAF entered Condition C of TS 3.3.2.1 for an inoperable Rod Worth Minimizer (RWM). Condition C restricts plant startup to once per calendar year without restoring the RWM system to operable. JAF conducted a plant startup from a planned refueling outage with the RWM inoperable on September 17, 2024. On September 23, 2024, at 07:20 JAF experienced an automatic SCRAM as a result of a main turbine trip due to an automatic trip of the generator output breakers (ENS #57333). The Nuclear Regulatory Commission (NRC) granted verbal approval of a Notice of Enforcement Discretion (NOED) on September 23, 2024, to allow JAF to conduct plant startup without having an operable RWM.
JAF is requesting approval of a license amendment on an expedited basis for TS 3.3.2.1 Control Rod Block Instrumentation. TS 3.3.2.1 Condition C.2.1.2 requires an operable RWM in Modes 1 and 2 while less than 10% Reactor Thermal Power (RTP) and permits only one startup per calendar year with the RWM inoperable. If the RWM is not restored to operable status, TS 3.3.2.1.C must be entered, requiring the following: verification that greater than twelve control rods are withdrawn OR verification by administrative methods that a reactor startup with RWM inoperable has not been performed in the current calendar year AND movement of control rods is within compliance with banked position withdrawal sequence (BPWS) by a second licensed operator or other qualified member of the technical staff.
This proposed amendment requests a temporary change to TS 3.3.2.1 Condition C for the operability of the RWM during reactor startup. The change adds a footnote to TS 3.3.2.1 Required Action C.2.1.2 which permits reactor startup with the RWM inoperable while the compensatory measure described in the Attachment 1, Section 3.5 to this letter is implemented. This allowance expires on December 31, 2024. This will provide time for the site to perform RWM software enhancements and adequately resolve the current RWM software issue.
2.0 DETAILED DESCRIPTION
2.1 Condition Description
At 22:54 on September 17, 2024, JAF entered Condition C of TS 3.3.2.1 for an inoperable RWM. Required Action C.2.1.2 restricts plant startup to once per calendar year without restoring the RWM system to operable. JAF conducted a plant startup from a planned refueling outage with the RWM inoperable on September 17, 2024. On September 23, 2024, at 07:20 JAF experienced an automatic SCRAM as a result of a main turbine trip due to an automatic trip of the generator output breakers (ENS #57333).
On September 23, 2024, the NRC)granted verbal approval of a NOED to allow JAF to conduct plant startup without having an operable RWM.
Evaluation of Proposed Changes Page 2 of 9
Currently, there is a software error in which the RWM is being forced to an inoperable state because of a timing issue with a Full Core Rod Scan resulting from an observed Rod Drift condition during rod movement. JAF is pursuing a solution for the software error.
The observed condition is the result of the RWM program enforcing rod blocks when the required action is permitted in compliance with the BPWS and unexpected program aborts related to momentary control rod drift alarms. The issues are confirmed to have originated from the RWM program, based on review of the RWM alarm screen. There are no concerns with other related structures, systems and components including control rod indication and controls.
2.2 Extent of Condition
JAF does not have a redundant RWM. The current issue is isolated to the RWM software only. No hardware issue has been observed.
2.3 System Design and Operation
An online process computer is provided to monitor and log process variables and to make certain analytical computations. The RWM function of the computer prevents rod withdrawal under low power conditions if the rod to be withdrawn is not in accordance with a preplanned pattern. The effect of the rod block is to limit the reactivity worth of the control rods by enforcing adherence to the preplanned rod pattern.
The RWM function assists and supplements the operator with a backup control rod monitoring routing that enforces adherence to established startup, shutdown and low power level control rod procedures. The computer prevents the control room operator from establishing control rod patterns that are not consistent with pre-stored RWM sequences by initiating appropriate rod withdrawal block and rod insert block interlock signals to the Reactor Manual Control System rod block circuitry. The RWM sequences stored in the computer memory are based on control rod withdrawal procedures designed to limit and, thereby, minimize individual control rod worths to acceptable levels as determined by the design basis rod drop accident.
The RWM function may be bypassed, and its block function disabled only by specific procedural control initiated by the shift manager.
Control rod withdrawal errors are considered when the reactor is at power levels below the power range. The most severe case occurs when the reactor is just critical at room temperature and an out-of-sequence rod is continuously withdrawn. Procedural controls supplemented by the RWM would normally prevent withdrawal of such a rod. It is assumed that the Intermediate Range Neutron Monitoring (IRM) channels are in the worst conditions of allowed bypass. The scaling arrangement of the IRMs is such that for unbypassed IRM channels a SCRAM signal is generated before the detected neutron flux has increased by more than a factor of ten. In addition, a high neutron flux SCRAM is generated by the average power range monitors.
Evaluation of Proposed Changes Page 3 of 9
2.4 Current Technical Specification Requirements
For continued rod movement with the RWM inoperable, TS 3.3.2.1 Condition C requires the following:
o verification that greater than or equal to twelve control rods are withdrawn OR o verification by administrative methods that startup with RWM inoperable has not been performed in the current calendar year.
AND o 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.
2.5 Reason for the Proposed Changes
Despite diligent and prudent efforts, JAF does not have the confidence of the software to keep the RWM in an operable condition. Therefore, CEG requests a temporary TS change to allow future plant startups with the RWM inoperable for the remainder of the current calendar year. This will provide time for the site to perform RWM software enhancements and adequately resolve the current RWM software issue.
2.6 Description of the Proposed Change
The following temporary changes are proposed to the JAF TS:
An asterisk is added to the TS page 3.3.2.1-2, TS 3.3.2.1 Condition C, Required Action C.2.1.2.
C. Rod worth minimizer C.1 Suspend control rod Immediately (RWM) inoperable during movement expect by reactor startup. scram.
C.2.1.1 Verify 12 rods Immediately withdrawn.
C.2.1.2 Verify by Immediately administrative methods that startup with RWM inoperable has not been performed in the current calendar year.
- AND
C.2.2 Verify movement of During control rod control rods is in movement
Evaluation of Proposed Changes Page 4 of 9
compliance with banked position withdrawal sequence (BPWS) by a second by a second licensed operator or other qualified member of the technical staff.
The associated footnote is placed at the bottom of TS page 3.3.2.1-2 :
- Reactor startup with the RWM inoperable is permitted while the compensatory measure described in letter JAFP-24-00 47 dated September 25, 2024, is implemented. This allowance expires on 12/31/2024 at 23:59.
3.0 TECHNICAL EVALUATION
3.1 Defense-in-Depth/Deterministic Evaluation
The RWM acts to limit the reactivity worth of control rods by enforcing adherence to a pre-planned rod pattern.
In an operating reactor, there is a spectrum of possible control rod worths, depending on the reactor state and on the control rod patterns chosen for operation. Control rod withdrawal sequences and patterns are selected prior to operation to achieve optimum core performance and, simultaneously, low individual rod worths. Distributed control rod patterns are used. The operating procedures to accomplish such patterns are supplemented by the RWM program of the process computer, which prevents rod withdrawals yielding a rod worth greater than permitted by the preselected rod withdrawal pattern.
The specified rod withdrawal sequences and the RWM maintain rod worth at acceptable low values to minimize the consequences of a reactivity accident. In accordance with the UFSAR, a limit on fuel enthalpy is imposed to ensure margin to excursion energies which may endanger the Reactor Coolant Pressure Boundary. The control rod sequences, in conjunction with the velocity limiter, an integral part of the control rod, ensure that peak fuel enthalpy remains within this limit.
Should the RWM program be inoperative for any reason, the control room operator can maintain acceptable rod worth by simply adhering to the prescribed control rod patterns and sequences when below 10 percent of rated power.
The control rod drop accident is defined as the assumed drop of the highest worth rod that can be developed at any time in core life or plant operating conditions by one error on the part of the operator. The RWM, which would normally prevent the operator from moving this rod, is assumed not to function.
The first barrier in preventing the establishment of high worth control rods is the reactor operator and the control rod withdrawal sequences. By procedures, the reactor operator follows the rod-by-rod withdrawal sequence provided by the reactor engineer. The RWM Evaluation of Proposed Changes Page 5 of 9
has been designed as a backup to the operator so that if procedures are violated, the RWM will block rod motion.
Provided that the RWM is unavailable when required by plant technical specifications (less than 10%), an additional Action is prescribed by the TS (TS 3.2.2.1, Condition C.2.2). The action includes stationing a second individual to ensure that the rod sequence is maintained. Plant procedures prohibit this individual from having other concurrent duties during withdrawal or insertion.
3.2 RWM Accident Analysis
In considering the possibilities of a control rod drop accident, only the rod worths of the lower curve of UFSAR Figure 14.6-1 are pertinent at less than 10 percent power. These are the rods which are normally allowed to be moved by operating procedures and the r RWM. The nonscheduled rods, those within the central envelope, do not have a withdrawal permissive during the time their worths are greater than the lower curve, so they are held full in by the control rod drive and cannot drop from the core. If a nonscheduled rod were selected, the RWM blocks rod movement. Therefore, the worth of the strongest rod which could be stuck is limited to about 0.01 k. The 0.025 k worth assumed for cases A and B is considerably above the rod worth values available for stuck rods under the assumed reactor conditions.
3.3 Safety Margin Evaluation
The requested change permits reactor startups in the 2024 calendar year with an inoperable RWM. This latitude relies upon the mitigating strategy described in Section 3.5 which is comprised of a compensatory measure in combination with existing TS actions and procedural requirements. This strategy acts to maintain control rod movement integrity and margin.
3.4 Risk Assessment
The RWM is a reactor protection system-related function which prevents operators from moving an incorrect control rod. Movement of a high-worth control rod could lead to a reactivity excursion and/or localized fuel clad integrity challenge and the RWM is designed to prevent such situations. Relative to the probabilistic risk assessment (PRA), the RWM is not modeled because if such an event were to occur, the Reactor SCRAM signal would ultimately protect the core from severe accident conditions. In the JAF PRA, the SCRAM system is modeled with Reactor Pressure and Reactor Water level signals such that if either functionality fails in response to an initiating event, an Anticipated Transient Without SCRAM (ATWS) scenario would occur. By modeling the reactor SCRAM function, the PRA addresses the significance of the Reactor Protection System and control rods relative to severe accidents. While the RWM can prevent reactivity excursions and fuel challenges, it provides no additional protection against severe accidents and is of negligible risk significance to public health and safety.
The proposed allowances will provide for startups with an inoperable RWM in the current calendar year, rather than the current limitation of a single startup with an inoperable RWM per calendar year. Rod withdrawal will be ensured to comply with the required sequence Evaluation of Proposed Changes Page 6 of 9
by a second licensed operator or member of the technical staff. These actions ensure compliance with a rod withdrawal sequence that mitigates the postulated core damage in the unlikely event of a rod drop accident at low power. These mitigating actions, in concert with the low likelihood of the initiating condition and the minimal increase in permitted frequency over the plant life will ensure there is no more than a minimal increase in radiological risk.
3.5 Mitigating Strategy
To reduce the likelihood of the applicable initiating event (incorrect rod movement while RWM is inoperable) JAF will use a mitigating strategy comprised of a compensatory measure in combination with existing TS actions and procedural requirement, as described below.
JAF will take the following compensatory measure:
- JAF will dedicate an independent third-party review of the rod movement sheets.
A third-party review of the control rod movement sheets is required to ensure compliance with the BPWS. The compensatory measure will add additional defense-in-depth.
Beyond the compensatory measure described above, the site will also take the existing TS 3.3.2.1 Action C.2.2 to have a second licensed operator or other qualified member of the technical staff verify movement of control rods is in compliance with BPWS.
In addition to the above TS required action, per procedure, control rod movement for startup will take place in accordance with BWR Control Rod Movement Requirements, OP-AB-300- 1001, which requires a second licensed operator to perform all Main Control Room peer checks per CEGs management model. Also, in accordance with CEGs management model, control rod movement during a startup is overseen by a dedicated Reactivity Management Senior Reactor Operator who acts to ensure all planned control rod movement is performed in accordance with approved procedures.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria
The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. CEG has determined that the proposed changes do not require any exemptions or relief from regulatory requirements from the following current applicable regulations and regulatory requirements which were reviewed in making this determination:
- 10 CFR, Section 50.36, "Technical specifications," in which the Commission established its regulatory requirements related to the contents of the TS.
Specifically, 10 CFR 50.36(c)(2) states, in part, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility." The proposed changes do not affect compliance with these regulations.
Evaluation of Proposed Changes Page 7 of 9
- 10 CFR 50 Appendix A, "General Design Criteria for Nuclear Power Plants,"
Criterion 26Reactivity control system redundancy and capability, states that two independent reactivity control systems of different design principles shall be provided. One of the systems shall use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions.
In conclusion, on the basis of 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 Commission's 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.
4.2 Precedent
Letter from Jack N. Donohew (NRC) to Mr. P. B. Fiedler, Oyster Creek Nuclear Station, Rod Worth Minimizer, dated November 7, 1986 (ML011160423)
4.3 Significant Hazards Consideration Analysis
Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).
This proposed amendment requests a temporary change to TS 3.3.2.1 Required Action C.2.1.2 for the operability of the Rod Worth Minimizer (RWM) during reactor startup. The change adds a footnote to TS 3.3.2.1 Required Action C.2.1.2 which permits reactor startup with the RWM inoperable while the compensatory measure described in the Attachment 1, Section 3.5 to this letter is implemented. This allowance expires on December 31, 2024. This will provide time for the site to perform RWM software enhancements and adequately resolve the current RWM software issue. This proposed amendment was discussed verbally with the NRC on September 24, 2024.
JAF 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:
Evaluation of Proposed Changes Page 8 of 9
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No
The proposed RWM bypass allowance does not involve the modification of any plant equipment or affect basic plant operation. The proposed allowances provide additional time to correct problems associated with the RWM. In the event the RWM is inoperable during reactor startup, the technical specification ensures that a licensed operator or other qualified member of the technical staff enforce compliance with the control rod position sequence developed using the banked position withdrawal sequence (BPWS). Applicable compensatory measures will be implemented in the event the RWM is inoperable.
The proposed change does not involve a change to the safety function of the RWM.
The proposed change involves no significant changes to the operations of any systems or component in normal or accident operating conditions.
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 accident from any accident previously evaluated?
Response: No
The proposed RWM bypass allowance is not a precursor to any accident previously evaluated. The proposed change provides additional time to rectify RWM equipment issues to ensure that the system implements the control rod pattern developed using BPWS methodology. The proposed change is not required to mitigate the accident conditions. The proposed change does not change the safety function. There is no alteration to the parameters within which the plant is normally operated. The RWM bypass allowance for additional startups is not a precursor to a new or different kind of accident and does not initiate new or different kinds of accidents. As a result, no new failure modes are being introduced.
Therefore, the proposed amendment will not create the possibility of a new or different accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The margin of safety is established through the design of the plant structures, systems, and components, and administrative controls within which the plant is operated. The margin of safety to the consequences of a control rod drop accident is maintained through the use of additional administrative controls described within the current technical specification. The establishment for the control rod insertion and withdrawal during the startups is manually controlled with independent verification by Evaluation of Proposed Changes Page 9 of 9
a second licensed reactor operator or other qualified member of the technical staff to ensure compliance with BPWS, if RWM becomes inoperable for any reason.
Therefore, the proposed change does not impact the design basis accidents. The proposed change does not change the requirements governing operation or availability of safety equipment assumed to operate to preserve the margin of safety.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above, JAF concludes that the proposed amendment does not involve a 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.
4.4 Conclusions
In conclusion, based on the considerations discussed herein, (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.
5.0 ENVIRONMENTAL CONSIDERATION
JAF has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types, or significant increase in the amounts, of any effluent that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, 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 impact statement or environmental assessment need be prepared in connection with the proposed amendment.
ATTACHMENT 2
James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR -59 Docket No. 50-333
REVISED TECHNICAL SPECIFICATIONS PAGES
3.3.2.1-2
ACTIONS CONDITION C.(continued)
D.RWM inoperable duringreactor shutdown.
JAFNPP Control Rod Block Instrumentation 3.3.2.1 REQUIRED ACTION COMPLETION TIME C.2.1.1 Verify 12 rods Immediately withdrawn.
OR -
C.2.1.2 Verify by Immediately AND -
C.2.2 During control rod movement D.l During control rod movement administrative methods that startup with RWM inoperable has not been performed in the current calendar year.
- Verify movement of control rods is in compliance with banked position withdrawal sequence CBPWS) by a second licensed operator or other qualified member of the technical staff.
Verify movement of control rods is in compliance with BPWS by a second licensed operator or other qualified member of the technical staff.
(continued) 3.3.2.1-2 Amendment 274