W3F1-2015-0079, Control Element Assembly Drop Times License Condition

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Control Element Assembly Drop Times License Condition
ML15281A223
Person / Time
Site: Waterford Entergy icon.png
Issue date: 10/08/2015
From: Chisum M
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2015-0079
Download: ML15281A223 (10)


Text

s Entergy Operations, Inc.

17265 River Road Killona, LA 70057 Tel 504 739 6660 Fax 504 739 6678 Michael R. Chisum Site Vice President Waterford 3 W3F1-2015-0079 October 8, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Control Element Assembly Drop Times License Condition Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. W3F1-2015-0040, License Amendment Request to Revise Control Element Drop Times, July 2, 2015 [ADAMS Accession Number ML15197A106].
2. W3F1-2015-0061, Supplement to Revise Control Element Assembly Drop Times Associated with Technical Specification 3.1.3.4, August 13, 2015 [ADAMS Accession Number ML15226A346].
3. NRC CEA Drop Time Submittal Request for Additional Information, August 26, 2015 [ADAMS Accession Number ML15232A275].
4. W3F1-2015-0062, Control Element Assembly Drop Times Submittal Request for Additional Information, September 23, 2015.

Dear Sir or Madam:

On July 2, 2015, Entergy Operations, Inc. (Entergy) requested an amendment to revise the Control Element Assembly (CEA) drop times associated with Technical Specification 3.1.3.4 for Waterford Steam Electric Station Unit 3 (Waterford 3) [Reference 1]. On August 13, 2015, Waterford 3 submitted a supplement [Reference 2] to provide additional accident scenario results to bound a possible increase in the control element assembly holding coil decay time. The Nuclear Regulatory Commission (NRC) requested additional information to aid in their review [Reference 3]. On September 23, 2015, Waterford 3 responded to the NRC request for additional information [Reference 4].

Waterford 3 letter W3F1-2015-0040 [Reference 1] Attachment 7 contained four commitments. After further discussions with the NRC, Waterford 3 is requesting that the second commitment be modified and changed to a license condition.

W3F1-2015-0079 Page 2 to this letter provides the markup of the Facility Operating License No. NPF-38 to include the proposed license condition. Attachment 2 contains a clean copy of the Facility Operating License No. NPF-38 change. Attachment 3 contains the Waterford 3 Updated Final Safety Analysis Report (UFSAR) markup of the new CEA drop time table.

This submittal does not alter the no significant hazards consideration or environmental assessment previously submitted by Waterford 3 in letter W3F1-2015-0040 [Reference 1].

If you have any questions or require additional information, please contact John Jarrell, Regulatory Assurance Manager, at 504-739-6685.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 8, 2015.

Sincerely, MRC/JPJ/wjs Attachments:

1. Facility Operating License No. NPF Markup
2. Facility Operating License No. NPF Clean Copy
3. Waterford 3 Updated Final Safety Analysis Report - Markup cc: Mr. Marc L. Dapas Regional Administrator U. S. NRC, Region IV RidsRgn4MailCenter@nrc.gov NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov (SRI)

Chris.Speer@nrc.gov (RI)

NRC Project Manager for Waterford 3 Michael.Orenak@nrc.gov Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division Ji.Wiley@LA.gov

Attachment 1 to W3F1-2015-0079 Facility Operating License No. NPF Markup This attachment contains 2 pages.

(a) The first performance of SR 6.5.17, in accordance with Specification 6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.5.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from August 13, 2008, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

20. Control Element Assembly Drop Time Curve Validation (Amendment XXX)

Add Prior to Cycle 21 Mode 2 operation, the licensee shall verify the control element assembly drop time test data demonstrates faster control element assembly drop times than the drop time curve provided in Table 15.0-5 of the Final Safety Analysis Report, as amended.

D. The facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section 6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

Paragraph E moved to next page.

AMENDMENT NO. 171, 218, 234, 239, 241, XXX Revised by letter dated July 26, 2007

Paragraph E moved from previous page.

E. EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency and Training & Qualification Plan," and was submitted on October 4, 2004.

EOI shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved by License Amendment No. 234 and supplemented by a change approved by Amendment No. 239 and 241.

F. Except as otherwise provided in the Technical Specifications or the Environmental Protection Plan, EOI shall report any violations of the requirements contained in Section 2.C of this license in the following manner.

Initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73(b), (c) and (e).

G. Entergy Louisiana, LLC shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This license is effective as the date of issuance and shall expire at midnight on December 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by H.R. Denton Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)
2. Attachment 2
3. Appendix A (Technical Specifications) (NUREG-1117)
4. Appendix B (Environmental Protection Plan)
5. Appendix C (Antitrust Conditions)

Date of Issuance: March 16, 1985 AMENDMENT NO. 218, XXX

Attachment 2 to W3F1-2015-0079 Facility Operating License No. NPF Clean Copy This attachment contains 2 pages.

(a) The first performance of SR 6.5.17, in accordance with Specification 6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.5.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from August 13, 2008, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

20. Control Element Assembly Drop Time Curve Validation (Amendment XXX)

Prior to Cycle 21 Mode 2 operation, the licensee shall verify the control element assembly drop time test data demonstrates faster control element assembly drop times than the drop time curve provided in Table 15.0-5 of the Final Safety Analysis Report, as amended.

D. The facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section 6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

AMENDMENT NO. 171, 218, 234, 239, 241, XXX Revised by letter dated July 26, 2007

E. EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency and Training & Qualification Plan," and was submitted on October 4, 2004.

EOI shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved by License Amendment No. 234 and supplemented by a change approved by Amendment No. 239 and 241.

F. Except as otherwise provided in the Technical Specifications or the Environmental Protection Plan, EOI shall report any violations of the requirements contained in Section 2.C of this license in the following manner.

Initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73(b), (c) and (e).

G. Entergy Louisiana, LLC shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This license is effective as the date of issuance and shall expire at midnight on December 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by H.R. Denton Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)
2. Attachment 2
3. Appendix A (Technical Specifications) (NUREG-1117)
4. Appendix B (Environmental Protection Plan)
5. Appendix C (Antitrust Conditions)

Date of Issuance: March 16, 1985 AMENDMENT NO. 218, XXX

Attachment 3 to W3F1-2015-0079 Waterford 3 Updated Final Safety Analysis Report - Markup This attachment contains 1 page.

WSES-FSAR-UNIT-3 TABLE 15.0-5 CHAPTER 15 AVERAGE CONTROL ELEMENT ASSEMBLY (CEA) INSERTION TIMES Average CEA Time Insertion (Seconds)

(%)

0 0.00 0 0.60 Add 5 0.95 10 1.15 20 1.45 30 1.75 40 2.00 50 2.25 60 2.50 70 2.75 80 2.95 90 3.20 100 3.50

s Entergy Operations, Inc.

17265 River Road Killona, LA 70057 Tel 504 739 6660 Fax 504 739 6678 Michael R. Chisum Site Vice President Waterford 3 W3F1-2015-0079 October 8, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Control Element Assembly Drop Times License Condition Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. W3F1-2015-0040, License Amendment Request to Revise Control Element Drop Times, July 2, 2015 [ADAMS Accession Number ML15197A106].
2. W3F1-2015-0061, Supplement to Revise Control Element Assembly Drop Times Associated with Technical Specification 3.1.3.4, August 13, 2015 [ADAMS Accession Number ML15226A346].
3. NRC CEA Drop Time Submittal Request for Additional Information, August 26, 2015 [ADAMS Accession Number ML15232A275].
4. W3F1-2015-0062, Control Element Assembly Drop Times Submittal Request for Additional Information, September 23, 2015.

Dear Sir or Madam:

On July 2, 2015, Entergy Operations, Inc. (Entergy) requested an amendment to revise the Control Element Assembly (CEA) drop times associated with Technical Specification 3.1.3.4 for Waterford Steam Electric Station Unit 3 (Waterford 3) [Reference 1]. On August 13, 2015, Waterford 3 submitted a supplement [Reference 2] to provide additional accident scenario results to bound a possible increase in the control element assembly holding coil decay time. The Nuclear Regulatory Commission (NRC) requested additional information to aid in their review [Reference 3]. On September 23, 2015, Waterford 3 responded to the NRC request for additional information [Reference 4].

Waterford 3 letter W3F1-2015-0040 [Reference 1] Attachment 7 contained four commitments. After further discussions with the NRC, Waterford 3 is requesting that the second commitment be modified and changed to a license condition.

W3F1-2015-0079 Page 2 to this letter provides the markup of the Facility Operating License No. NPF-38 to include the proposed license condition. Attachment 2 contains a clean copy of the Facility Operating License No. NPF-38 change. Attachment 3 contains the Waterford 3 Updated Final Safety Analysis Report (UFSAR) markup of the new CEA drop time table.

This submittal does not alter the no significant hazards consideration or environmental assessment previously submitted by Waterford 3 in letter W3F1-2015-0040 [Reference 1].

If you have any questions or require additional information, please contact John Jarrell, Regulatory Assurance Manager, at 504-739-6685.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 8, 2015.

Sincerely, MRC/JPJ/wjs Attachments:

1. Facility Operating License No. NPF Markup
2. Facility Operating License No. NPF Clean Copy
3. Waterford 3 Updated Final Safety Analysis Report - Markup cc: Mr. Marc L. Dapas Regional Administrator U. S. NRC, Region IV RidsRgn4MailCenter@nrc.gov NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov (SRI)

Chris.Speer@nrc.gov (RI)

NRC Project Manager for Waterford 3 Michael.Orenak@nrc.gov Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division Ji.Wiley@LA.gov

Attachment 1 to W3F1-2015-0079 Facility Operating License No. NPF Markup This attachment contains 2 pages.

(a) The first performance of SR 6.5.17, in accordance with Specification 6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.5.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from August 13, 2008, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

20. Control Element Assembly Drop Time Curve Validation (Amendment XXX)

Add Prior to Cycle 21 Mode 2 operation, the licensee shall verify the control element assembly drop time test data demonstrates faster control element assembly drop times than the drop time curve provided in Table 15.0-5 of the Final Safety Analysis Report, as amended.

D. The facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section 6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

Paragraph E moved to next page.

AMENDMENT NO. 171, 218, 234, 239, 241, XXX Revised by letter dated July 26, 2007

Paragraph E moved from previous page.

E. EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency and Training & Qualification Plan," and was submitted on October 4, 2004.

EOI shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved by License Amendment No. 234 and supplemented by a change approved by Amendment No. 239 and 241.

F. Except as otherwise provided in the Technical Specifications or the Environmental Protection Plan, EOI shall report any violations of the requirements contained in Section 2.C of this license in the following manner.

Initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73(b), (c) and (e).

G. Entergy Louisiana, LLC shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This license is effective as the date of issuance and shall expire at midnight on December 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by H.R. Denton Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)
2. Attachment 2
3. Appendix A (Technical Specifications) (NUREG-1117)
4. Appendix B (Environmental Protection Plan)
5. Appendix C (Antitrust Conditions)

Date of Issuance: March 16, 1985 AMENDMENT NO. 218, XXX

Attachment 2 to W3F1-2015-0079 Facility Operating License No. NPF Clean Copy This attachment contains 2 pages.

(a) The first performance of SR 6.5.17, in accordance with Specification 6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.5.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from August 13, 2008, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

20. Control Element Assembly Drop Time Curve Validation (Amendment XXX)

Prior to Cycle 21 Mode 2 operation, the licensee shall verify the control element assembly drop time test data demonstrates faster control element assembly drop times than the drop time curve provided in Table 15.0-5 of the Final Safety Analysis Report, as amended.

D. The facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section 6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

AMENDMENT NO. 171, 218, 234, 239, 241, XXX Revised by letter dated July 26, 2007

E. EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency and Training & Qualification Plan," and was submitted on October 4, 2004.

EOI shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved by License Amendment No. 234 and supplemented by a change approved by Amendment No. 239 and 241.

F. Except as otherwise provided in the Technical Specifications or the Environmental Protection Plan, EOI shall report any violations of the requirements contained in Section 2.C of this license in the following manner.

Initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73(b), (c) and (e).

G. Entergy Louisiana, LLC shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This license is effective as the date of issuance and shall expire at midnight on December 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by H.R. Denton Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)
2. Attachment 2
3. Appendix A (Technical Specifications) (NUREG-1117)
4. Appendix B (Environmental Protection Plan)
5. Appendix C (Antitrust Conditions)

Date of Issuance: March 16, 1985 AMENDMENT NO. 218, XXX

Attachment 3 to W3F1-2015-0079 Waterford 3 Updated Final Safety Analysis Report - Markup This attachment contains 1 page.

WSES-FSAR-UNIT-3 TABLE 15.0-5 CHAPTER 15 AVERAGE CONTROL ELEMENT ASSEMBLY (CEA) INSERTION TIMES Average CEA Time Insertion (Seconds)

(%)

0 0.00 0 0.60 Add 5 0.95 10 1.15 20 1.45 30 1.75 40 2.00 50 2.25 60 2.50 70 2.75 80 2.95 90 3.20 100 3.50