ML082320016

Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency Using the Consolidated Line Item Improvement Process

ML082320016
Person / Time
Site:	Nine Mile Point
Issue date:	08/18/2008
From:	Belcher S Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML082320016 (14)

Text

Sam L. Belcher P.O. Box 63 Plant General Manager Lycoming, New York 13093 315.349.5205 315.349.1321 Fax

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Nine Mile Point Nuclear Station August 18,2008 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit No.1; Docket No. 50-220 Renewed Facility Operating License No. DPR-63 Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) is submitting a request for an amendment to the Technical Specifications (TS) for Nine Mile Point Unit 1 (NMP1).

The proposed amendment would revise the TS surveillance requirement (SR) frequency in TS 3/4.1.1, "Control Rod System."

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS page marked-up to show the proposed change. Associated TS Bases changes are marked-up in Attachment 3. The TS Bases changes are provided for information only and will be processed in accordance with the NMP1 TS 6.5.6, "Technical Specifications (TS) Bases Control Program." Attachment 4 provides a summary of the regulatory commitments made in this submittal.

NMPNS requests approval of the proposed License Amendment by February 16, 2009, with the amendment being implementation within 60 days of approval of the amendment.

In accordance with 10 CFR 50.91, NMPNS has provided a copy of this license amendment request, with attachments, to the appropriate state representative.

Document Control Desk August 18, 2008 Page 2 Should you have any questions regarding the information in this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219.

Very truly yours, STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Sam L. Belcher, being duly sworn, state that I am Plant General Manager, and that I am duly authorized to execute and file this request on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Oswego, this 181L day of ~ 2008.

WITNESS my Hand and Notarial Seal:

Notary u ic My Commission Expires:

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Attachments: 1. Description and Assessment

2. Proposed Technical Specifications Changes (Marked-Up Page)

3. Proposed Technical Specifications Bases Changes (Marked-Up Page)

4. Summary of Regulatory Commitments Made in this Submittal

Document Control Desk August 18,2008 Page 3 cc: S. J. Collins, NRC Regional Administrator, Region I R. V. Guzman, Jr., NRC Project Manager E. C. Knutson, Senior NRC Resident Inspector J. P. Spath, NYSERDA

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT TABLE OF CONTENTS

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 ENVIRONMENTAL EVALUATION Nine Mile Point Nuclear Station, LLC August 18, 2008

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendment would revise Nine Mile Point Unit 1 (NMP1) Technical Specifications (TS)

Section 3/4.1.1, "Control Rod System" to increase the surveillance requirement (SR) frequency associated with control rod exercising. Currently, SR 4.1.1a.(2) requires each partially or fully withdrawn control rod to be exercised at least once each week (7 days). The proposed change would revise the required SR frequency from once each week to once every 31 days.

This change is consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-475, Revision 1, and NUREG-1433, "Standard Technical Specifications General Electric Plants, BWR/4," Revision 3.1.

The Federal Register Notice published on November 13, 2007 announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Nine Mile Point Nuclear Station, LLC (NMPNS) has reviewed the safety evaluation dated November 13, 2007 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-475, Revision 1. NMPNS has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to NMPI and justify this amendment for the incorporation of the changes to the NMPI TS.

2.2 Optional Changes and Variations The NMPI is a custom Technical Specifications plant and, therefore, the applicable TS and associated Bases sections are not formatted in accordance with NUREG-1433 for BWR/4 plants. This has resulted in minor variations to the NMPI adoption of TSTF-475 that are grammatical and administrative in nature and do not alter or change the technical intent of the changes proposed for control rod operability surveillance frequency requirements for SR 4.1.1a.(2).

Additionally, the revised notch testing frequency addressed in TSTF-475, Revision 1 is specific to fully withdrawn control rods, since partially withdrawn control rods already have a 31 day test frequency as contained in Standard Technical Specifications (NUREG-1433, Revision 3.1). Currently, NMPI TS SR 4.1.1a.(2) requires partially withdrawn control rods to be exercised at least once each week. The proposed NMPI amendment addresses changes to include "withdrawn control rods" (inclusive of fully and partially withdrawn). The change is based upon STS and TSTF-475, Revision 1.

The purpose of the weekly surveillance for notch testing partially withdrawn control rods is the same as for fully withdrawn control rods, that is, to confirm control rod insertion capability. Based upon industry operating experience, as discussed in the safety evaluation for TSTF-475, Revision 1, a stuck control rod is an extremely rare event. Also, as discussed in the safety evaluation, the proposed change from a weekly to a monthly test frequency has been determined to be acceptable based on demonstrated historical reliability of the Control Rod Drive System and that monthly testing will still provide a large number of tests to provide confidence that any problems with the system would be identified. The industry operating experience is inclusive of notch testing of both partially and fully withdrawn control rods.

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ATTACHMENT 1 DESCRIPTION AND ASSESSMENT In support of this test frequency change, an editorial change was also included in SR 4.1.Ia.(2) to detail the conditions required to perform the SR, as provided by the NRC Model Safety Evaluation for TSTF-475, Revision I. Specifically, the minimum power level conditions (power level greater than the low power set point of the Rod Worth Minimizer) and minimum control rod withdrawal limits (at least one notch) have been included in the SR.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Nine Mile Point Nuclear Station (NMPNS) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the consolidated line item improvement process (CLIIP). NMPNS has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Nine Mile Point Unit 1 (NMPI) and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

The proposed change would also revise the surveillance requirement (SR) frequency for exercising partially withdrawn control rods from weekly to monthly. NMPNS has reviewed the NSHCD published in the Federal Register as part of the CLIIP and concluded it adequately describes changing the notch testing requirement from weekly to monthly for all control rods (partially or fully withdrawn).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on November 13, 2007 for this TS improvement, NMPNS has verified the applicability of TSTF-475 to NMPI, and commits to establishing Technical Specification Bases for the TS as proposed in TSTF-475, Revision 1 as described in this license amendment request.

This change is based on TSTF change traveler TSTF-475 (Revision 1) that proposes revisions to the STS by revising the frequency of SR 3/4.1.1, notch testing of a withdrawn control rod, from "7 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of RWM" to "31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP ofRWM."

4.0 ENVIRONMENTAL EVALUATION NMPNS has reviewed the environmental evaluation included in the model safety evaluation dated November 13, 2007 as part of the CLIIP. NMPNS has concluded that the staffs findings presented in that evaluation are applicable to NMPI and the evaluation is hereby incorporated by reference for this application.

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ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARKED-UP PAGE)

TS Page 30 Nine Mile Point Nuclear Station, LLC August 18, 2008

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT secondary containment penetration flow path not isolated.

(e) If Specification 3.1.1a(1)(a) is not met while in the refueling condition, then:

Immediately suspend core alterations, except for fuel assembly removal, and Immediately initiate action to fully insert all insertable control rods in core cells y5fJ containing one or more fuel assemblies.

(2) Reactivity margin - stuck control rods Control rods which cannot be moved with control rod drive pressure shall be considered inoperable. Inoperable control rods shall be

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or valved out of service, in such positions that Specification 3.1.1a(1)(a) is met. In no case shall the number of non-fully inserted rods valved out of service be greater than six during power operation. If this specification is not met, the reactor shall be placed in the cold shutdown condition. If a partially or fully withdrawn control rod drive cannot be moved with drive or scram pressure the reactor shall be brought to a shutdown condition within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> unless investigation demonstrates that the cause of the failure is not due to a failed control rod drive mechanism collet housing.

AMENDMENT NO. -'t-42-,-+ae-) 30

INSERT:

Each withdrawn control rod shall be exercised at a frequency of 31 days after the control rod has been withdrawn and power level is greater than the low power set point of the RWM. Insert each withdrawn control rod at least one notch.

ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS BASES CHANGES (MARKED-UP PAGE)

TS Bases Page 38 Nine Mile Point Nuclear Station, LLC August 18, 2008

BASES FOR 3.1.1 AND 4.1.1 CONTROL ROD SYSTEM The allowable inoperable rod patterns will be determined using information obtained in the startup test program supplemented by calculations. During initial startup, the reactivity condition of the as-built core will be determined.

Also, sub-critical patterns of widely separated withdrawn control rods will be observed in the control rod sequences being used. The observations, together with calculated strengths of the strongest control rods in these patterns will comprise a set of allowable separations of malfunctioning rods. During the fuel cycle, similar observations made during any cold shutdown can be used to update and/or increase the allowable patterns. .

Also if dam ge within, the co rol rod drive me anism and in p icular, cracks' drive intern housings, canno be

rl'~r+-  :,.. ruled out hen a generic pr lem affecting a nnot be ruled ut. Circumfe ntial cracks resu ng from s ess assisted inter anular corrosion ave occurred in e collet housi of drives at everal SWRs. Thi type of crac ng could occur in number of drive and if the crack propagated un severance of he collet housing ccurred, sc m could be prev ted in the affecte rods. Limiting e period of op ation with a tentially severed IIet ousing and requiri g increased survei ance after detec ng one stuck r (j will assure at the reactor will ot be operated with a rge number of ro with failed colle housings.

b. Control Rod Withdrawal (1) Control rod dropout accidents as discussed in Appendix E

• can lead to significant core damage. If coupling integrity is maintained, the possibility of a rod dropout accident is eliminated. The overtravel position feature provides a positive check as only uncoupled drives may reach this position. Neutron instrumentation response to rod movement provides an indirect verification that the rod is coupled to its drive. Details of the control rod drive coupling are given in Section IV.B.6.1 -.

• FSAR AMENDMENT NO.~.1 38

INSERT:

Control rod insertion capability is demonstrated by inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves. The control rod may then be returned to its original position. This ensures that the control rod is not stuck and is free to insert on a scram signal. This surveillance is not required when thermal power is less than or equal to the low power set point (LPSP) of the RWM, since notch insertion may not be compatible with the requirements of the RWM. The 31 day surveillance test frequency takes into account operating experience related to changes in CRD performance. This surveillance requirement allows 31 days after withdrawal of the control rod concurrent with thermal power greater than the LPSP of the RWM to perform the surveillance.

The requirement to exercise control rods at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the event power operation is continuing with two or more control rods which are valved out of service or one fully or partially withdrawn control rod which can not be moved, provides a reasonable time to test the control rods and provide assurance of the reliability of the remaining control rods.

ATTACHMENT 4

SUMMARY

OF REGULATORY COMMITMENTS MADE IN THIS SUBMITTAL Nine Mile Point Nuclear Station, LLC August 18, 2008

ATTACHMENT 4

SUMMARY

OF REGULATORY COMMITMENTS MADE IN THIS SUBMITTAL LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by NMPNS in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to T. F. Syrell, Licensing Director, at (315) 349-5219.

REGULATORY COMMITMENT DUE DATE/EVENT NMPNS will establish the Technical Specifications Bases for This commitment will be TS 3/4.1.1 consistent with those shown in TSTF-475, Revision implemented within ,60 days from 1, "Control Rod Notch Testing Frequency and SRM Insert the date of the approval of the Control Rod Action" as described in the license amendment proposed amendment.

request.

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