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| number = ML072750394 | | number = ML072750394 | ||
| issue date = 11/05/2007 | | issue date = 11/05/2007 | ||
| title = | | title = License Amendment, Issuance of Amendment Control Rod Operability, Scram Insertion Time, and Control Rod Accumulator Requirements | ||
| author name = Kim J | | author name = Kim J | ||
| author affiliation = NRC/NRR/ADRO/DORL/LPLI-1 | | author affiliation = NRC/NRR/ADRO/DORL/LPLI-1 | ||
| addressee name = Balduzzi M | | addressee name = Balduzzi M | ||
| addressee affiliation = Entergy Nuclear Operations, Inc | | addressee affiliation = Entergy Nuclear Operations, Inc | ||
| docket = 05000293 | | docket = 05000293 | ||
Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter:November 5, 2007 | {{#Wiki_filter:November 5, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc. | ||
440 Hamilton Avenue White Plains, NY 10601 | |||
Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc. | |||
440 Hamilton Avenue White Plains, NY | |||
==SUBJECT:== | ==SUBJECT:== | ||
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: | PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: | ||
CONTROL ROD OPERABILITY, SCRAM INSERTION TIME, AND CONTROL ROD ACCUMULATOR REQUIREMENTS (TAC NO. MD4242) | |||
==Dear Mr. Balduzzi:== | ==Dear Mr. Balduzzi:== | ||
The Commission has issued the enclosed Amendment No. 230 to Facility | The Commission has issued the enclosed Amendment No. 230 to Facility Operating License No. | ||
DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated January 4, 2007. | |||
This amendment provides changes to revise the Technical Specifications for the Limiting Conditions for Operation and Surveillance Requirements for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulators. | This amendment provides changes to revise the Technical Specifications for the Limiting Conditions for Operation and Surveillance Requirements for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulators. | ||
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice. | |||
A copy of the related Safety | Sincerely, | ||
Sincerely, | /RA/ | ||
James S. Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293 | |||
Docket No. 50-293 | |||
==Enclosures:== | ==Enclosures:== | ||
: 1. Amendment No. 230 to License No. DPR-35 | : 1. Amendment No. 230 to License No. DPR-35 | ||
: 2. Safety Evaluation | : 2. Safety Evaluation cc w/encls: See next page | ||
cc w/encls: | |||
Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc. | November 5, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc. | ||
440 Hamilton Avenue White Plains, NY | 440 Hamilton Avenue White Plains, NY 10601 | ||
==SUBJECT:== | ==SUBJECT:== | ||
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: | PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: | ||
CONTROL ROD OPERABILITY, SCRAM INSERTION TIME, AND CONTROL ROD ACCUMULATOR REQUIREMENTS (TAC NO. MD4242) | |||
==Dear Mr. Balduzzi:== | ==Dear Mr. Balduzzi:== | ||
The Commission has issued the enclosed Amendment No. 230 to Facility | The Commission has issued the enclosed Amendment No. 230 to Facility Operating License No. | ||
DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated January 4, 2007. | |||
This amendment provides changes to revise the Technical Specifications for the Limiting Conditions for Operation and Surveillance Requirements for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulators. | This amendment provides changes to revise the Technical Specifications for the Limiting Conditions for Operation and Surveillance Requirements for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulators. | ||
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice. | |||
A copy of the related Safety | Sincerely, | ||
Sincerely, | /RA/ | ||
James S. Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293 | |||
Docket No. 50-293 | |||
==Enclosures:== | ==Enclosures:== | ||
: 1. Amendment No. 230 to License No. DPR-35 | : 1. Amendment No. 230 to License No. DPR-35 | ||
: 2. Safety Evaluation | : 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION: | ||
PUBLIC RPowell, RI RidsOGC RP GCranston RidsNrrDorlLpl1-1 SLittle JKim GHill (2) TNakanishi RidsAcrsAcnwMail Package No.: ML072750429 Amendment No.: ML072750394 Tech Spec No.: ML OFFICE LPLI-1/PM LPLI-1/LA SBWC/BC OGC LPL1-1/BC NAME JKim SLittle GCranston MBaty MKowal DATE 10/10/07 10/10/07 10/16/07 10/17/07 11/02/07 OFFICIAL RECORD COPY | |||
cc w/encls: | |||
Package No.: ML072750429 Amendment No.: ML072750394 | |||
Pilgrim Nuclear Power Station cc: | |||
: | Regional Administrator, Region I U. S. Nuclear Regulatory Commission Director, Massachusetts Emergency 475 Allendale Road Management Agency King of Prussia, PA 19406-1415 Attn: James Muckerheide 400 Worcester Road Senior Resident Inspector Framingham, MA 01702-5399 U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Mr. William D. Meinert Post Office Box 867 Nuclear Engineer Plymouth, MA 02360 Massachusetts Municipal Wholesale Electric Company Chairman, Board of Selectmen P.O. Box 426 11 Lincoln Street Ludlow, MA 01056-0426 Plymouth, MA 02360 Mr. Kevin H. Bronson Chairman Site Vice President Nuclear Matters Committee Entergy Nuclear Operations Town Hall Pilgrim Nuclear Power Station 11 Lincoln Street 600 Rocky Hill Road Plymouth, MA 02360 Plymouth, MA 02360-5508 Chairman, Duxbury Board of Selectmen Mr. Robert G. Smith Town Hall General Manager, Plant Operations 878 Tremont Street Entergy Nuclear Operations Duxbury, MA 02332 Pilgrim Nuclear Power Station 600 Rocky Hill Road Office of the Commissioner Plymouth, MA 02360-5508 Massachusetts Department of Environmental Protection Mr. Stephen J. Bethay One Winter Street Director, Nuclear Safety Assurance Boston, MA 02108 Entergy Nuclear Operations Pilgrim Nuclear Power Station Office of the Attorney General 600 Rocky Hill Road One Ashburton Place Plymouth, MA 02360-5508 20th Floor Boston, MA 02108 Mr. Bryan S. Ford Manager, Licensing MA Department of Public Health Entergy Nuclear Operations Radiation Control Program Pilgrim Nuclear Power Station Schrafft Center, Suite 1M2A 600 Rocky Hill Road 529 Main Street Plymouth, MA 02360-5508 Charlestown, MA 02129 | ||
A. | Pilgrim Nuclear Power Station cc: | ||
Mr. John T. Herron Ms. Charlene D. Faison Sr. Vice President Manager, Licensing Entergy Nuclear Operations Entergy Nuclear Operations 1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. Oscar Limpias Mr. Ernest J. Harkness Vice President, Engineering Director, Oversight Entergy Nuclear Operations Entergy Nuclear Operations, Inc. | |||
440 Hamilton Avenue 1340 Echelon Parkway White Plains, NY 10601 Jackson, MS 39213 Mr. John A. Ventosa Mr. William C. Dennis GM, Engineering Assistant General Counsel Entergy Nuclear Operations Entergy Nuclear Operations 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Joseph P. DeRoy Ms. Stacey Lousteau VP, Operations Support Treasury Department Entergy Operations, Inc. Entergy Services, Inc. | |||
1340 Echelon parkway 639 Loyola Avenue Jackson, MS 39213 New Orleans, LA 70113 Mr. Michael Kansler Mr. James Sniezek President & CEO/CNO 5486 Nithsdale Drive Entergy Nuclear Operations Salisbury, MD 21801-2490 1340 Echelon Parkway Jackson, MS 39213 Mr. Michael D. Lyster 5931 Barclay Lane Mr. John F. McCann Naples, FL 34110-7306 Director, Nuclear Safety & Licensing Entergy Nuclear Operations Mr. Garrett D. Edwards 440 Hamilton Avenue 814 Waverly Road White Plains, NY 10601 Kennett Square, PA 19348 Mr. John Doering P.O. Box 189 Parker Ford, PA 19457 | |||
public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. | ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC. | ||
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the | DOCKET NO. 50-293 PILGRIM NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 230 License No. DPR-35 | ||
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 230, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications. | : 1. The Nuclear Regulatory Commission (the Commission) has found that: | ||
A. The application for amendment filed by Entergy Nuclear Operations, Inc. (the licensee) dated January 4, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. | |||
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-35 is hereby amended to read as follows: | |||
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 230, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications. | |||
: 3. This license amendment is effective as of the date of issuance and shall be implemented within 120 days. | : 3. This license amendment is effective as of the date of issuance and shall be implemented within 120 days. | ||
FOR THE NUCLEAR REGULATORY COMMISSION | FOR THE NUCLEAR REGULATORY COMMISSION | ||
/RA/ | |||
Mark Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation | |||
==Attachment:== | ==Attachment:== | ||
Changes to the License and Technical Specifications | Changes to the License and Technical Specifications Date of Issuance: November 5, 2007 | ||
Date of Issuance: | |||
FACILITY OPERATING LICENSE NO. DPR-35 | ATTACHMENT TO LICENSE AMENDMENT NO. 230 FACILITY OPERATING LICENSE NO. DPR-35 DOCKET NO. 50-293 Replace the following page of the Facility Operating License with the attached revised page. | ||
The revised page is identified by amendment number and contains marginal lines indicating the areas of change. | |||
Remove Insert 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. | |||
Remove Insert i i 3/4.3-2 3/4.3-2 3/4.3-3 3/4.3-3 3/4.3-4 3/4.3-4 3/4.3-6 3/4.3-6 3/4.3-7 3/4.3-7 3/4.3-8 3/4.3-8 3/4.3-9 3/4.3-9 | |||
DOCKET NO. 50-293 | SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 230 TO FACILITY OPERATING LICENSE NO. DPR-35 ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC. | ||
PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 | |||
==1.0 INTRODUCTION== | |||
By letter dated January 4, 2007, (Reference 1), Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Technical Specifications (TSs) for Pilgrim Nuclear Power Station (PNPS). The proposed changes revise TS that involve Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SR) applicable to Control Rod Operability in TS 3/4.3.B; Scram Insertion Times in TS 3/4.3.C; and Control Rod Accumulators in TS 3/4.3.D. The primary purpose of the proposed change is to revise TS 3/4.3.C to change the required control rod scram time test frequency interval from "within each 120 days of operation at-power" to "within each 200 days of cumulative operation in RUN." This change is consistent with Consolidated Line Item Improvement Process (CLIIP) Notice of Availability, dated August 23, 2004 (69 FR 51864) and Technical Specification Task Force change traveler TSTF-460, Rev. 0. The secondary purpose of the proposed change is to revise TS 3/4.3.B, TS 3/4.3.C, and TS 3/4.3.D to ensure consistency with NUREG-1433, Revision 3, "Standard Technical Specifications (STS), | |||
General Electric Plant, BWR/4," specifications 3.1.3, 3.1.4, and 3.1.5. The STS format changes involve adoption of a revised control rod scram time test methodology. The proposed scram time test criterion (TS 3/4.3.C) evaluates control rod operability based on capability of individual control rods to meet established scram times. The existing TS requirements for averaging all operable control rod scram times and for grouped array averaging of multiple control rod scram times are removed. The proposed scram time test criterion establishes a new category of operable but "slow" control rods and establishes allowable limits for the number and distribution of these "slow" rods. | |||
==2.0 REGULATORY EVALUATION== | |||
==2.0 REGULATORY EVALUATION== | |||
The TS governing the control rod scram time surveillance is intended to assure proper function of control rod insertion. Following each refueling outage, all control rod scram times are verified. | The TS governing the control rod scram time surveillance is intended to assure proper function of control rod insertion. Following each refueling outage, all control rod scram times are verified. | ||
In addition, periodically during power operation, a representative sample of control rods is selected to be inserted to verify the insertion speed. | In addition, periodically during power operation, a representative sample of control rods is selected to be inserted to verify the insertion speed. | ||
rods scram at a specified insertion rate. Operability of each individual | 2 A representative sample is defined as a sample containing at least 10 percent of the total number of control rods. The current TS stipulates that no more than 20 percent of the control rods in this representative sample can be slow'' during the post outage testing. With more than 20 percent of the sample declared to be slow'' per the criteria in Table 3.1.4-1, additional control rods are tested until this 20 percent criterion (e.g., 20 percent of the entire sample size) is satisfied, or until the total number of slow'' control rods (throughout the core, from all surveillances) exceeds the LCO limit. For planned testing, the control rods selected for the sample should be different for each test. The acceptance criterion for at-power surveillance testing has been redefined from 20 percent to 7.5 percent. This tightened acceptance criterion for at-power surveillance aligns with the TS 3.1.4 requirement for the total control rods allowed to have scram times exceeding the specified limit. | ||
The control rod scram accumulators are part of the control rod drive (CRD) system and are provided to ensure that the control rods scram under varying reactor conditions. The control rod scram accumulators store sufficient energy to fully insert a control rod at any reactor vessel pressure. The design-basis accident (DBA) and transient analyses assume that all of the control rods scram at a specified insertion rate. Operability of each individual control rod scram accumulator helps ensure that the scram reactivity assumed in the DBA and transient analyses can be met. The existence of an inoperable accumulator may invalidate prior scram time measurements for the associated control rod. The actions being revised address the options for declaring control rods associated with inoperable accumulators as either slow or inoperable. | |||
==3.0 TECHNICAL EVALUATION== | ==3.0 TECHNICAL EVALUATION== | ||
The license amendment request (LAR) proposes changes to the PNPS TSs in three main areas, 1) Control Rod Operability as described in TS LCO Section 3.3.B and TS SR Section 4.3.B, 2) Scram Insertion Times as described in TS LCO Section 3.3.C and TS SR Section 4.3.C, and 3) Control Rod Accumulators as described in TS LCO Section 3.3.D and SR Section 4.3.D. | The license amendment request (LAR) proposes changes to the PNPS TSs in three main areas, 1) Control Rod Operability as described in TS LCO Section 3.3.B and TS SR Section 4.3.B, 2) Scram Insertion Times as described in TS LCO Section 3.3.C and TS SR Section 4.3.C, and 3) Control Rod Accumulators as described in TS LCO Section 3.3.D and SR Section 4.3.D. | ||
Its primary purpose is to revise TS SR 4.3.C to change the required control rod scram time testing frequency interval from Awithin each 120 days of operation at-power | Its primary purpose is to revise TS SR 4.3.C to change the required control rod scram time testing frequency interval from Awithin each 120 days of operation at-power@ to Awithin each 200 days of cumulative operation in RUN.@ This change is consistent with TSTF-460, Rev. 0 (Reference 3). | ||
@ to Awithin each 200 days of cumulative operation in RUN. | |||
@ | |||
Its secondary purpose is to revise the other LCOs and SRs in TS 3.3 and 4.3 to be consistent with NUREG-1433, Rev. 3, AStandard Technical Specifications (STS), General Electric Plant, BWR/4@ (Reference 2). | Its secondary purpose is to revise the other LCOs and SRs in TS 3.3 and 4.3 to be consistent with NUREG-1433, Rev. 3, AStandard Technical Specifications (STS), General Electric Plant, BWR/4@ (Reference 2). | ||
Each change is discussed and evaluated below. | Each change is discussed and evaluated below. | ||
3.1 TS LCO 3.3.B.1 Action A.1 The proposed change revises the action statement to require operators to Averify stuck control rod separation criteria are met immediately. | 3.1 TS LCO 3.3.B.1 Action A.1 The proposed change revises the action statement to require operators to Averify stuck control rod separation criteria are met immediately.@ This change to reference the stuck control rod separation criteria, newly defined in the TS Bases 3/4.3.B.1 Actions A.1, A.2, A.3, and A.4, is needed with the introduction of a new control rod operability criterion which defines Aslow@ but operable control rods and the corresponding stuck rod separation criteria now based on Aslow@ | ||
@ | but operable control rods. This change is consistent with STS Bases 3.1.3 and the new stuck | ||
3.2 TS SR 4.3.B.1.4 The proposed change revises the SR section to identify the additional | |||
3.3 TS LCO 3.3.C The proposed change revises the current TS LCO 3.3.C.1 and TS LCO 3.3.C.2 to identify a new scram time acceptance criteria which allows a condition where a control rod may be considered Aslow@ but still operable. | 3 rod separation criteria will continue to meet the local scram reactivity rate assumptions in the licensing basis analysis. In addition, the Nuclear Regulatory Commission (NRC) staff concludes that the new control rod operability criterion is acceptable, as evaluated in Section 3.3 of this safety evaluation (SE). Therefore, the NRC staff finds the proposed change to TS LCO Section 3.3.B.1 Action A.1 and associated stuck rod separation criteria acceptable. | ||
The proposed change adopts a different testing method to determine if the measured scram insertion times are sufficient to provide sufficient negative reactivity assumed in the licensing basis analysis. The LAR references BWROG-8754, dated September 1987 (Reference 4) as the bases for the proposed TS LCO 3.3.C approach. The current LCO requires two sets of scram insertion time tables, one identifying the average scram insertion times for all operable control rods and one identifying the average scram insertion times for the three fastest operable control rods in all two by two arrays. The proposal simplifies the approach by introducing one scram insertion time table which identifies any control rod not within the specified scram insertion times as Aslow.@ | 3.2 TS SR 4.3.B.1.4 The proposed change revises the SR section to identify the additional surveillance tests based on the new TS SR 4.3.C. The NRC staff finds the new TS SR 4.3.C acceptable, as discussed in Sections 3.4 and 3.5 of this SE. Therefore, the NRC staff finds the proposed change to TS SR Section 4.3.B.1.4 acceptable. | ||
@ of multiple rods. Furthermore, it identifies any control rod with scram times > 7 seconds to notch position 04 as inoperable. The revised LCO would allow no more than 10 control rods (or 7 percent of 145) to be Aslow@ and allows no more than two operable but Aslow@ control rods to occupy adjacent locations. The proposed scram insertion time table also identifies the tests that should be performed on fully withdrawn rods and defines the criteria based on reactor steam dome pressure. | 3.3 TS LCO 3.3.C The proposed change revises the current TS LCO 3.3.C.1 and TS LCO 3.3.C.2 to identify a new scram time acceptance criteria which allows a condition where a control rod may be considered Aslow@ but still operable. | ||
The purpose of TS LCO 3.3.C is to ensure that the negative scram reactivity assumptions in the licensing basis analysis are supported by the actual scram performance of the individual control rods. The methodology used in the licensing basis analysis assumes all control rods scram at the same speed (i.e., the analytical scram time). The licensing basis analysis that is performed on a cycle specific basis will assume the TS scram time limits. Therefore, if all control rods scram at least as fast as the proposed TS time limits, then the analytical scram reactivity curve will be met. It is recognized that for a situation where individual control rods do not satisfy the time limits, the condition may be acceptable if the resulting scram reactivity still meets or exceeds the analytical scram reactivity curve where slower | The proposed change adopts a different testing method to determine if the measured scram insertion times are sufficient to provide sufficient negative reactivity assumed in the licensing basis analysis. The LAR references BWROG-8754, dated September 1987 (Reference 4) as the bases for the proposed TS LCO 3.3.C approach. The current LCO requires two sets of scram insertion time tables, one identifying the average scram insertion times for all operable control rods and one identifying the average scram insertion times for the three fastest operable control rods in all two by two arrays. The proposal simplifies the approach by introducing one scram insertion time table which identifies any control rod not within the specified scram insertion times as Aslow.@ This change to base the scram time acceptability on individual control rod performance also eliminates the concern of potentially allowing operation with too many Aslow@ rods because a few fast scramming rods were available to provide an acceptable Aaverage time@ of multiple rods. Furthermore, it identifies any control rod with scram times > 7 seconds to notch position 04 as inoperable. The revised LCO would allow no more than 10 control rods (or 7 percent of 145) to be Aslow@ and allows no more than two operable but Aslow@ control rods to occupy adjacent locations. The proposed scram insertion time table also identifies the tests that should be performed on fully withdrawn rods and defines the criteria based on reactor steam dome pressure. | ||
The purpose of TS LCO 3.3.C is to ensure that the negative scram reactivity assumptions in the licensing basis analysis are supported by the actual scram performance of the individual control rods. The methodology used in the licensing basis analysis assumes all control rods scram at the same speed (i.e., the analytical scram time). The licensing basis analysis that is performed on a cycle specific basis will assume the TS scram time limits. Therefore, if all control rods scram at least as fast as the proposed TS time limits, then the analytical scram reactivity curve will be met. It is recognized that for a situation where individual control rods do not satisfy the time limits, the condition may be acceptable if the resulting scram reactivity still meets or exceeds the analytical scram reactivity curve where slower control rods are compensated by faster control rods. The analysis discussed in Reference 3 provides that the | |||
4 analytical scram reactivity curve will be satisfied if no more than 7 percent of the rods are slow and these slow rods are distributed in satisfactory manner. Reference 3 has been previously reviewed and approved by the NRC staff and has been incorporated into the STS. It is the current control rod operability basis for many of the operating boiling-water reactors. | |||
Based on above, there is reasonable assurance that applying the revised TS LCO 3.3.C approach to PNPS will not adversely impact its ability to remain within the licensing basis analysis envelope. Therefore, the NRC staff finds the proposed change to TS LCO 3.3.C acceptable. | Based on above, there is reasonable assurance that applying the revised TS LCO 3.3.C approach to PNPS will not adversely impact its ability to remain within the licensing basis analysis envelope. Therefore, the NRC staff finds the proposed change to TS LCO 3.3.C acceptable. | ||
3.4 TS SR 4.3.C.1 The proposed change replaces the current TS SR 4.3.C.1 with three SRs (TS SR 4.3.C.1, | 3.4 TS SR 4.3.C.1 The proposed change replaces the current TS SR 4.3.C.1 with three SRs (TS SR 4.3.C.1, TS SR 4.3.C.3, and TS SR 4.3.C.4) consistent with STS 3.1.4. The three SRs will continue to address the current TS SR 4.3.C.1 requirement of scram testing the operable rods prior to exceeding 40 percent rated thermal power following a refueling outage or an extended outage greater than 120 days. The change separates the current SR into two SRs, creating one SR to be performed following an extended outage and another SR to be performed following a normal refueling outage. The change also imposes an additional SR to perform scram testing on rods affected by control rod or CRD system work prior to declaring the rod(s) operable. | ||
3.5 TS SR 4.3.C.2 The proposed change revises the current TS SR 4.3.C.2 to extend the at-power scram time test frequency from Awithin 120 days of operation | Relative to the current TS, more conservative provisions are included in the revision to perform scram testing with CRD pumps isolated and reactor pressure greater than or equal to 800 psig. Having the CRD pump isolated ensures that associated pump head will not influence the scram testing. The proposed change to revise reactor pressure requirement from > 950 psig to $ 800 psig is more conservative because the maximum scram times occur at reactor pressure of approximately 800 psig. The proposed changes will continue to satisfy the current requirements and provide additional conservatism. Therefore, the NRC staff finds the proposed change to TS SR 4.3.C.1 acceptable. | ||
@ to Awithin each 200 days of cumulative operation in RUN. | 3.5 TS SR 4.3.C.2 The proposed change revises the current TS SR 4.3.C.2 to extend the at-power scram time test frequency from Awithin 120 days of operation@ to Awithin each 200 days of cumulative operation in RUN.@ | ||
The existing TS SR 4.3.C.2 requires that scram testing be performed on 10 percent of the CRDs within each 120 days of operation. The frequency of 120 days is proposed to be changed to 200 days based on industry experience demonstrating that scram times do not significantly change over an operating cycle. The licensee evaluated the historical performance of the PNPS CRD scram times over the past five cycles. The data showed that out of 1890 individual CRD scram time tests, there were no instances of inoperable control rods (i.e. > 7 sec) and only six instances where an individual CRD did not meet the revised scram time (i.e., the CRD would be considered Aslow@). The NRC staff concurs that the historical data justifies the reliability of scram capability. In addition, this change, which is addressed in TSTF-460, Rev. 0 (Reference 3), has been previously reviewed and approved by the NRC staff and has been incorporated into the STS. Many of the current operating boiling-water reactors operate under this approach. The NRC staff finds the proposed change to TS SR 4.3.C.2 acceptable. | |||
5 | 5 3.6 TS SR 4.3.D The current TS SR 4.3.D does not identify an explicit criterion for accumulator operability. | ||
The proposed change revises the current TS SR 4.3.D to explicitly define the accumulator operability criterion based on a minimum of 940 psig accumulator pressure. This value is based on the equipment specification and testing data. The proposed change also defines the surveillance frequency as every 7 days. This is consistent with STS 3.1.5. The NRC staff finds the proposed change to TS SR 4.3.D acceptable. | |||
3.7 TS LCO 3.3.D Actions A, B, C, D, and E The proposed TS LCO 3.3.D Action A addresses the condition where one control rod accumulator is inoperable when the reactor pressure is $ 950 psig. It is important to note that at reactor pressures $ 950 psig, the control rod will scram even without the accumulator available, albeit not with the required scram times. The proposed change revises the current TS LCO 3.3.D Action A to provide an option to declare a control rod with inoperable accumulator, Aslow@ within 8 hours. The 8-hour completion time is viewed as reasonable based on availability of large number of control rods to provide the scram function. The ability to declare Aslow@ rods is allowed only for control rods not previously know to be Aslow,@ since additional degradation by an inoperable accumulator must be prevented for an already Aslow@ | |||
rod. This change is consistent with STS 3.1.5. The NRC staff finds the proposed change to TS LCO 3.3.D Action A acceptable. | |||
TS LCO 3.3.D Action B is deleted. The purpose of the current TS LCO 3.3.D Action B is to address the condition where reactor pressure is < 950 psig. This condition is now addressed in the revised TS LCO 3.3.D Action C. This change is consistent with STS 3.1.5. The NRC staff finds the proposed deletion of TS LCO 3.3.D Action B acceptable. | TS LCO 3.3.D Action B is deleted. The purpose of the current TS LCO 3.3.D Action B is to address the condition where reactor pressure is < 950 psig. This condition is now addressed in the revised TS LCO 3.3.D Action C. This change is consistent with STS 3.1.5. The NRC staff finds the proposed deletion of TS LCO 3.3.D Action B acceptable. | ||
The proposed TS LCO 3.3.D Action B now addresses the condition where two or more control rod accumulators are inoperable when the reactor pressure is | The proposed TS LCO 3.3.D Action B now addresses the condition where two or more control rod accumulators are inoperable when the reactor pressure is $ 950 psig. The same option to allow control rods to be declared Aslow@ is provided as the proposed TS LCO 3.3.D Action A, but the required completion time is reduced to 1 hour. This completion time is reasonable based on the ability of the reactor pressure to scram the rods and the anticipated low probability of a DBA or transient occurring while the affected accumulator is inoperable. | ||
The proposed change also ensures that the current TS LCO 3.3.D Action C.1 requirement continues to be satisfied by requiring the restoration of charging water header pressure to $ | |||
940 psig be attempted within 20 minutes. This change is consistent with STS 3.1.5. The NRC staff finds the proposed TS LCO 3.3.D Action B acceptable. | |||
The proposed TS LCO 3.3.D Action C addresses the condition where additional accumulators may become unavailable due to loss of charging water header pressure coincident with reactor dome pressure < 950 psig. The operators are instructed to fully insert all associated control rods and declare the associated rod inoperable. There is no technical change relative to the current TS associated with proposed TS LCO 3.3.D Action C. This change is consistent with STS 3.1.5. The NRC staff finds this change acceptable. | The proposed TS LCO 3.3.D Action C addresses the condition where additional accumulators may become unavailable due to loss of charging water header pressure coincident with reactor dome pressure < 950 psig. The operators are instructed to fully insert all associated control rods and declare the associated rod inoperable. There is no technical change relative to the current TS associated with proposed TS LCO 3.3.D Action C. This change is consistent with STS 3.1.5. The NRC staff finds this change acceptable. | ||
The proposed change to TS LCO 3.3.D Action D (which was Action E) is editorial to ensure that the action statements are correctly referenced. The NRC staff finds this change acceptable. | The proposed change to TS LCO 3.3.D Action D (which was Action E) is editorial to ensure that the action statements are correctly referenced. The NRC staff finds this change acceptable. | ||
6 | |||
== | ==4.0 STATE CONSULTATION== | ||
In accordance with the Commission's regulations, the Massachusetts State official was notified of the proposed issuance of the amendment. The State official had no comments. | |||
== | ==5.0 ENVIRONMENTAL CONSIDERATION== | ||
The Commission has | The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (72 FR 20381). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment. | ||
==6.0 CONCLUSION== | |||
The Commission has concluded, based on the considerations discussed above, that: (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. | |||
: 1 | |||
Date: | ==7.0 REFERENCES== | ||
: 1. Letter from M. Balduzzi (Entergy) to U.S. NRC, ARequest for License Amendment Technical Specification Revisions for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulator Requirements,@ dated January 4, 2007, Agencywide Documents Access and Management System (ADAMS) Accession Number ML070110501. | |||
: 2. NUREG-1433, Standard Technical Specifications for General Electric Plants BWR/4, Revision 3, March 2004. | |||
: 3. Improved Standard Technical Specifications Change Traveler TSTF-460, Rev. 0. | |||
: 4. BWROG-8754, letter from R.F. Janecek (BWROG) to R.W. Starostecki (NRC), dated September 17, 1987. | |||
Principal Contributor: T. Nakanishi Date: November 5, 2007}} |
Latest revision as of 02:13, 23 November 2019
ML072750394 | |
Person / Time | |
---|---|
Site: | Pilgrim |
Issue date: | 11/05/2007 |
From: | James Kim NRC/NRR/ADRO/DORL/LPLI-1 |
To: | Balduzzi M Entergy Nuclear Operations |
kim J, NRR/ADRO/DORL, 415-4125 | |
References | |
TAC MD4242 | |
Download: ML072750394 (6) | |
Text
November 5, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:
CONTROL ROD OPERABILITY, SCRAM INSERTION TIME, AND CONTROL ROD ACCUMULATOR REQUIREMENTS (TAC NO. MD4242)
Dear Mr. Balduzzi:
The Commission has issued the enclosed Amendment No. 230 to Facility Operating License No.
DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated January 4, 2007.
This amendment provides changes to revise the Technical Specifications for the Limiting Conditions for Operation and Surveillance Requirements for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulators.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.
Sincerely,
/RA/
James S. Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosures:
- 1. Amendment No. 230 to License No. DPR-35
- 2. Safety Evaluation cc w/encls: See next page
November 5, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:
CONTROL ROD OPERABILITY, SCRAM INSERTION TIME, AND CONTROL ROD ACCUMULATOR REQUIREMENTS (TAC NO. MD4242)
Dear Mr. Balduzzi:
The Commission has issued the enclosed Amendment No. 230 to Facility Operating License No.
DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated January 4, 2007.
This amendment provides changes to revise the Technical Specifications for the Limiting Conditions for Operation and Surveillance Requirements for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulators.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.
Sincerely,
/RA/
James S. Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosures:
- 1. Amendment No. 230 to License No. DPR-35
- 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC RPowell, RI RidsOGC RP GCranston RidsNrrDorlLpl1-1 SLittle JKim GHill (2) TNakanishi RidsAcrsAcnwMail Package No.: ML072750429 Amendment No.: ML072750394 Tech Spec No.: ML OFFICE LPLI-1/PM LPLI-1/LA SBWC/BC OGC LPL1-1/BC NAME JKim SLittle GCranston MBaty MKowal DATE 10/10/07 10/10/07 10/16/07 10/17/07 11/02/07 OFFICIAL RECORD COPY
Pilgrim Nuclear Power Station cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission Director, Massachusetts Emergency 475 Allendale Road Management Agency King of Prussia, PA 19406-1415 Attn: James Muckerheide 400 Worcester Road Senior Resident Inspector Framingham, MA 01702-5399 U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Mr. William D. Meinert Post Office Box 867 Nuclear Engineer Plymouth, MA 02360 Massachusetts Municipal Wholesale Electric Company Chairman, Board of Selectmen P.O. Box 426 11 Lincoln Street Ludlow, MA 01056-0426 Plymouth, MA 02360 Mr. Kevin H. Bronson Chairman Site Vice President Nuclear Matters Committee Entergy Nuclear Operations Town Hall Pilgrim Nuclear Power Station 11 Lincoln Street 600 Rocky Hill Road Plymouth, MA 02360 Plymouth, MA 02360-5508 Chairman, Duxbury Board of Selectmen Mr. Robert G. Smith Town Hall General Manager, Plant Operations 878 Tremont Street Entergy Nuclear Operations Duxbury, MA 02332 Pilgrim Nuclear Power Station 600 Rocky Hill Road Office of the Commissioner Plymouth, MA 02360-5508 Massachusetts Department of Environmental Protection Mr. Stephen J. Bethay One Winter Street Director, Nuclear Safety Assurance Boston, MA 02108 Entergy Nuclear Operations Pilgrim Nuclear Power Station Office of the Attorney General 600 Rocky Hill Road One Ashburton Place Plymouth, MA 02360-5508 20th Floor Boston, MA 02108 Mr. Bryan S. Ford Manager, Licensing MA Department of Public Health Entergy Nuclear Operations Radiation Control Program Pilgrim Nuclear Power Station Schrafft Center, Suite 1M2A 600 Rocky Hill Road 529 Main Street Plymouth, MA 02360-5508 Charlestown, MA 02129
Pilgrim Nuclear Power Station cc:
Mr. John T. Herron Ms. Charlene D. Faison Sr. Vice President Manager, Licensing Entergy Nuclear Operations Entergy Nuclear Operations 1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. Oscar Limpias Mr. Ernest J. Harkness Vice President, Engineering Director, Oversight Entergy Nuclear Operations Entergy Nuclear Operations, Inc.
440 Hamilton Avenue 1340 Echelon Parkway White Plains, NY 10601 Jackson, MS 39213 Mr. John A. Ventosa Mr. William C. Dennis GM, Engineering Assistant General Counsel Entergy Nuclear Operations Entergy Nuclear Operations 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Joseph P. DeRoy Ms. Stacey Lousteau VP, Operations Support Treasury Department Entergy Operations, Inc. Entergy Services, Inc.
1340 Echelon parkway 639 Loyola Avenue Jackson, MS 39213 New Orleans, LA 70113 Mr. Michael Kansler Mr. James Sniezek President & CEO/CNO 5486 Nithsdale Drive Entergy Nuclear Operations Salisbury, MD 21801-2490 1340 Echelon Parkway Jackson, MS 39213 Mr. Michael D. Lyster 5931 Barclay Lane Mr. John F. McCann Naples, FL 34110-7306 Director, Nuclear Safety & Licensing Entergy Nuclear Operations Mr. Garrett D. Edwards 440 Hamilton Avenue 814 Waverly Road White Plains, NY 10601 Kennett Square, PA 19348 Mr. John Doering P.O. Box 189 Parker Ford, PA 19457
ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.
DOCKET NO. 50-293 PILGRIM NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 230 License No. DPR-35
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment filed by Entergy Nuclear Operations, Inc. (the licensee) dated January 4, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-35 is hereby amended to read as follows:
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 230, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of the date of issuance and shall be implemented within 120 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Mark Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the License and Technical Specifications Date of Issuance: November 5, 2007
ATTACHMENT TO LICENSE AMENDMENT NO. 230 FACILITY OPERATING LICENSE NO. DPR-35 DOCKET NO. 50-293 Replace the following page of the Facility Operating License with the attached revised page.
The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove Insert 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert i i 3/4.3-2 3/4.3-2 3/4.3-3 3/4.3-3 3/4.3-4 3/4.3-4 3/4.3-6 3/4.3-6 3/4.3-7 3/4.3-7 3/4.3-8 3/4.3-8 3/4.3-9 3/4.3-9
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 230 TO FACILITY OPERATING LICENSE NO. DPR-35 ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.
PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
By letter dated January 4, 2007, (Reference 1), Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Technical Specifications (TSs) for Pilgrim Nuclear Power Station (PNPS). The proposed changes revise TS that involve Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SR) applicable to Control Rod Operability in TS 3/4.3.B; Scram Insertion Times in TS 3/4.3.C; and Control Rod Accumulators in TS 3/4.3.D. The primary purpose of the proposed change is to revise TS 3/4.3.C to change the required control rod scram time test frequency interval from "within each 120 days of operation at-power" to "within each 200 days of cumulative operation in RUN." This change is consistent with Consolidated Line Item Improvement Process (CLIIP) Notice of Availability, dated August 23, 2004 (69 FR 51864) and Technical Specification Task Force change traveler TSTF-460, Rev. 0. The secondary purpose of the proposed change is to revise TS 3/4.3.B, TS 3/4.3.C, and TS 3/4.3.D to ensure consistency with NUREG-1433, Revision 3, "Standard Technical Specifications (STS),
General Electric Plant, BWR/4," specifications 3.1.3, 3.1.4, and 3.1.5. The STS format changes involve adoption of a revised control rod scram time test methodology. The proposed scram time test criterion (TS 3/4.3.C) evaluates control rod operability based on capability of individual control rods to meet established scram times. The existing TS requirements for averaging all operable control rod scram times and for grouped array averaging of multiple control rod scram times are removed. The proposed scram time test criterion establishes a new category of operable but "slow" control rods and establishes allowable limits for the number and distribution of these "slow" rods.
2.0 REGULATORY EVALUATION
The TS governing the control rod scram time surveillance is intended to assure proper function of control rod insertion. Following each refueling outage, all control rod scram times are verified.
In addition, periodically during power operation, a representative sample of control rods is selected to be inserted to verify the insertion speed.
2 A representative sample is defined as a sample containing at least 10 percent of the total number of control rods. The current TS stipulates that no more than 20 percent of the control rods in this representative sample can be slow during the post outage testing. With more than 20 percent of the sample declared to be slow per the criteria in Table 3.1.4-1, additional control rods are tested until this 20 percent criterion (e.g., 20 percent of the entire sample size) is satisfied, or until the total number of slow control rods (throughout the core, from all surveillances) exceeds the LCO limit. For planned testing, the control rods selected for the sample should be different for each test. The acceptance criterion for at-power surveillance testing has been redefined from 20 percent to 7.5 percent. This tightened acceptance criterion for at-power surveillance aligns with the TS 3.1.4 requirement for the total control rods allowed to have scram times exceeding the specified limit.
The control rod scram accumulators are part of the control rod drive (CRD) system and are provided to ensure that the control rods scram under varying reactor conditions. The control rod scram accumulators store sufficient energy to fully insert a control rod at any reactor vessel pressure. The design-basis accident (DBA) and transient analyses assume that all of the control rods scram at a specified insertion rate. Operability of each individual control rod scram accumulator helps ensure that the scram reactivity assumed in the DBA and transient analyses can be met. The existence of an inoperable accumulator may invalidate prior scram time measurements for the associated control rod. The actions being revised address the options for declaring control rods associated with inoperable accumulators as either slow or inoperable.
3.0 TECHNICAL EVALUATION
The license amendment request (LAR) proposes changes to the PNPS TSs in three main areas, 1) Control Rod Operability as described in TS LCO Section 3.3.B and TS SR Section 4.3.B, 2) Scram Insertion Times as described in TS LCO Section 3.3.C and TS SR Section 4.3.C, and 3) Control Rod Accumulators as described in TS LCO Section 3.3.D and SR Section 4.3.D.
Its primary purpose is to revise TS SR 4.3.C to change the required control rod scram time testing frequency interval from Awithin each 120 days of operation at-power@ to Awithin each 200 days of cumulative operation in RUN.@ This change is consistent with TSTF-460, Rev. 0 (Reference 3).
Its secondary purpose is to revise the other LCOs and SRs in TS 3.3 and 4.3 to be consistent with NUREG-1433, Rev. 3, AStandard Technical Specifications (STS), General Electric Plant, BWR/4@ (Reference 2).
Each change is discussed and evaluated below.
3.1 TS LCO 3.3.B.1 Action A.1 The proposed change revises the action statement to require operators to Averify stuck control rod separation criteria are met immediately.@ This change to reference the stuck control rod separation criteria, newly defined in the TS Bases 3/4.3.B.1 Actions A.1, A.2, A.3, and A.4, is needed with the introduction of a new control rod operability criterion which defines Aslow@ but operable control rods and the corresponding stuck rod separation criteria now based on Aslow@
but operable control rods. This change is consistent with STS Bases 3.1.3 and the new stuck
3 rod separation criteria will continue to meet the local scram reactivity rate assumptions in the licensing basis analysis. In addition, the Nuclear Regulatory Commission (NRC) staff concludes that the new control rod operability criterion is acceptable, as evaluated in Section 3.3 of this safety evaluation (SE). Therefore, the NRC staff finds the proposed change to TS LCO Section 3.3.B.1 Action A.1 and associated stuck rod separation criteria acceptable.
3.2 TS SR 4.3.B.1.4 The proposed change revises the SR section to identify the additional surveillance tests based on the new TS SR 4.3.C. The NRC staff finds the new TS SR 4.3.C acceptable, as discussed in Sections 3.4 and 3.5 of this SE. Therefore, the NRC staff finds the proposed change to TS SR Section 4.3.B.1.4 acceptable.
3.3 TS LCO 3.3.C The proposed change revises the current TS LCO 3.3.C.1 and TS LCO 3.3.C.2 to identify a new scram time acceptance criteria which allows a condition where a control rod may be considered Aslow@ but still operable.
The proposed change adopts a different testing method to determine if the measured scram insertion times are sufficient to provide sufficient negative reactivity assumed in the licensing basis analysis. The LAR references BWROG-8754, dated September 1987 (Reference 4) as the bases for the proposed TS LCO 3.3.C approach. The current LCO requires two sets of scram insertion time tables, one identifying the average scram insertion times for all operable control rods and one identifying the average scram insertion times for the three fastest operable control rods in all two by two arrays. The proposal simplifies the approach by introducing one scram insertion time table which identifies any control rod not within the specified scram insertion times as Aslow.@ This change to base the scram time acceptability on individual control rod performance also eliminates the concern of potentially allowing operation with too many Aslow@ rods because a few fast scramming rods were available to provide an acceptable Aaverage time@ of multiple rods. Furthermore, it identifies any control rod with scram times > 7 seconds to notch position 04 as inoperable. The revised LCO would allow no more than 10 control rods (or 7 percent of 145) to be Aslow@ and allows no more than two operable but Aslow@ control rods to occupy adjacent locations. The proposed scram insertion time table also identifies the tests that should be performed on fully withdrawn rods and defines the criteria based on reactor steam dome pressure.
The purpose of TS LCO 3.3.C is to ensure that the negative scram reactivity assumptions in the licensing basis analysis are supported by the actual scram performance of the individual control rods. The methodology used in the licensing basis analysis assumes all control rods scram at the same speed (i.e., the analytical scram time). The licensing basis analysis that is performed on a cycle specific basis will assume the TS scram time limits. Therefore, if all control rods scram at least as fast as the proposed TS time limits, then the analytical scram reactivity curve will be met. It is recognized that for a situation where individual control rods do not satisfy the time limits, the condition may be acceptable if the resulting scram reactivity still meets or exceeds the analytical scram reactivity curve where slower control rods are compensated by faster control rods. The analysis discussed in Reference 3 provides that the
4 analytical scram reactivity curve will be satisfied if no more than 7 percent of the rods are slow and these slow rods are distributed in satisfactory manner. Reference 3 has been previously reviewed and approved by the NRC staff and has been incorporated into the STS. It is the current control rod operability basis for many of the operating boiling-water reactors.
Based on above, there is reasonable assurance that applying the revised TS LCO 3.3.C approach to PNPS will not adversely impact its ability to remain within the licensing basis analysis envelope. Therefore, the NRC staff finds the proposed change to TS LCO 3.3.C acceptable.
3.4 TS SR 4.3.C.1 The proposed change replaces the current TS SR 4.3.C.1 with three SRs (TS SR 4.3.C.1, TS SR 4.3.C.3, and TS SR 4.3.C.4) consistent with STS 3.1.4. The three SRs will continue to address the current TS SR 4.3.C.1 requirement of scram testing the operable rods prior to exceeding 40 percent rated thermal power following a refueling outage or an extended outage greater than 120 days. The change separates the current SR into two SRs, creating one SR to be performed following an extended outage and another SR to be performed following a normal refueling outage. The change also imposes an additional SR to perform scram testing on rods affected by control rod or CRD system work prior to declaring the rod(s) operable.
Relative to the current TS, more conservative provisions are included in the revision to perform scram testing with CRD pumps isolated and reactor pressure greater than or equal to 800 psig. Having the CRD pump isolated ensures that associated pump head will not influence the scram testing. The proposed change to revise reactor pressure requirement from > 950 psig to $ 800 psig is more conservative because the maximum scram times occur at reactor pressure of approximately 800 psig. The proposed changes will continue to satisfy the current requirements and provide additional conservatism. Therefore, the NRC staff finds the proposed change to TS SR 4.3.C.1 acceptable.
3.5 TS SR 4.3.C.2 The proposed change revises the current TS SR 4.3.C.2 to extend the at-power scram time test frequency from Awithin 120 days of operation@ to Awithin each 200 days of cumulative operation in RUN.@
The existing TS SR 4.3.C.2 requires that scram testing be performed on 10 percent of the CRDs within each 120 days of operation. The frequency of 120 days is proposed to be changed to 200 days based on industry experience demonstrating that scram times do not significantly change over an operating cycle. The licensee evaluated the historical performance of the PNPS CRD scram times over the past five cycles. The data showed that out of 1890 individual CRD scram time tests, there were no instances of inoperable control rods (i.e. > 7 sec) and only six instances where an individual CRD did not meet the revised scram time (i.e., the CRD would be considered Aslow@). The NRC staff concurs that the historical data justifies the reliability of scram capability. In addition, this change, which is addressed in TSTF-460, Rev. 0 (Reference 3), has been previously reviewed and approved by the NRC staff and has been incorporated into the STS. Many of the current operating boiling-water reactors operate under this approach. The NRC staff finds the proposed change to TS SR 4.3.C.2 acceptable.
5 3.6 TS SR 4.3.D The current TS SR 4.3.D does not identify an explicit criterion for accumulator operability.
The proposed change revises the current TS SR 4.3.D to explicitly define the accumulator operability criterion based on a minimum of 940 psig accumulator pressure. This value is based on the equipment specification and testing data. The proposed change also defines the surveillance frequency as every 7 days. This is consistent with STS 3.1.5. The NRC staff finds the proposed change to TS SR 4.3.D acceptable.
3.7 TS LCO 3.3.D Actions A, B, C, D, and E The proposed TS LCO 3.3.D Action A addresses the condition where one control rod accumulator is inoperable when the reactor pressure is $ 950 psig. It is important to note that at reactor pressures $ 950 psig, the control rod will scram even without the accumulator available, albeit not with the required scram times. The proposed change revises the current TS LCO 3.3.D Action A to provide an option to declare a control rod with inoperable accumulator, Aslow@ within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8-hour completion time is viewed as reasonable based on availability of large number of control rods to provide the scram function. The ability to declare Aslow@ rods is allowed only for control rods not previously know to be Aslow,@ since additional degradation by an inoperable accumulator must be prevented for an already Aslow@
rod. This change is consistent with STS 3.1.5. The NRC staff finds the proposed change to TS LCO 3.3.D Action A acceptable.
TS LCO 3.3.D Action B is deleted. The purpose of the current TS LCO 3.3.D Action B is to address the condition where reactor pressure is < 950 psig. This condition is now addressed in the revised TS LCO 3.3.D Action C. This change is consistent with STS 3.1.5. The NRC staff finds the proposed deletion of TS LCO 3.3.D Action B acceptable.
The proposed TS LCO 3.3.D Action B now addresses the condition where two or more control rod accumulators are inoperable when the reactor pressure is $ 950 psig. The same option to allow control rods to be declared Aslow@ is provided as the proposed TS LCO 3.3.D Action A, but the required completion time is reduced to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This completion time is reasonable based on the ability of the reactor pressure to scram the rods and the anticipated low probability of a DBA or transient occurring while the affected accumulator is inoperable.
The proposed change also ensures that the current TS LCO 3.3.D Action C.1 requirement continues to be satisfied by requiring the restoration of charging water header pressure to $
940 psig be attempted within 20 minutes. This change is consistent with STS 3.1.5. The NRC staff finds the proposed TS LCO 3.3.D Action B acceptable.
The proposed TS LCO 3.3.D Action C addresses the condition where additional accumulators may become unavailable due to loss of charging water header pressure coincident with reactor dome pressure < 950 psig. The operators are instructed to fully insert all associated control rods and declare the associated rod inoperable. There is no technical change relative to the current TS associated with proposed TS LCO 3.3.D Action C. This change is consistent with STS 3.1.5. The NRC staff finds this change acceptable.
The proposed change to TS LCO 3.3.D Action D (which was Action E) is editorial to ensure that the action statements are correctly referenced. The NRC staff finds this change acceptable.
6
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Massachusetts State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (72 FR 20381). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (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.
7.0 REFERENCES
- 1. Letter from M. Balduzzi (Entergy) to U.S. NRC, ARequest for License Amendment Technical Specification Revisions for Control Rod Operability, Scram Insertion Times, and Control Rod Accumulator Requirements,@ dated January 4, 2007, Agencywide Documents Access and Management System (ADAMS) Accession Number ML070110501.
- 2. NUREG-1433, Standard Technical Specifications for General Electric Plants BWR/4, Revision 3, March 2004.
- 3. Improved Standard Technical Specifications Change Traveler TSTF-460, Rev. 0.
- 4. BWROG-8754, letter from R.F. Janecek (BWROG) to R.W. Starostecki (NRC), dated September 17, 1987.
Principal Contributor: T. Nakanishi Date: November 5, 2007