ML15281A223

Waterford, Unit 3 - Control Element Assembly Drop Times License Condition

ML15281A223
Person / Time
Site:	Waterford
Issue date:	10/08/2015
From:	Chisum M R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2015-0079
Download: ML15281A223 (10)

Text

s W3F1-2015-0079 October 8, 2015U.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 ReviseControl Element Drop Times, July 2, 2015 [ADAMS Accession Number ML15197A106].2. W3F1-2015-0061, Supplement to Revise Control ElementAssembly Drop Times Associated with TechnicalSpecification 3.1.3.4, August 13, 2015 [ADAMS Accession Number ML15226A346].3. NRC CEA Drop Time Submittal Request for AdditionalInformation, August 26, 2015 [ADAMS Accession Number ML15232A275].4. W3F1-2015-0062, Control Element Assembly Drop TimesSubmittal Request for Additional Information, September 23, 2015.

Dear Sir or Madam:

On July 2, 2015, Entergy Operations, Inc. (Entergy) requested an amendment to revise theControl Element Assembly (CEA) drop times associated with Technical Specification3.1.3.4 for Waterford Steam Electric Station Unit 3 (Waterford 3) [Reference 1]. On August13, 2015, Waterford 3 submitted a supplement [Reference 2] to provide additional accidentscenario results to bound a possible increase in the control element assembly holding coildecay time. The Nuclear Regulatory Commission (NRC) requested additional informationto 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 fourcommitments. After further discussions with the NRC, Waterford 3 is requesting that thesecond commitment be modified and changed to a license condition.Entergy Operations, Inc.

17265 River Road Killona, LA 70057Tel 504 739 6660Fax 504 739 6678 Michael R. ChisumSite Vice President Waterford 3 W3F1-2015-0079 Page 2Attachment 1 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 theFacility Operating License No. NPF-38 change. Attachment 3 contains the Waterford 3Updated Final Safety Analysis Report (UFSAR) markup of the new CEA drop time table.This submittal does not alter the no significant hazards consideration or environmentalassessment 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 Markup2. Facility Operating License No. NPF Clean Copy3. Waterford 3 Updated Final Safety Analysis Report - Markupcc: 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 3Michael.Orenak@nrc.gov Louisiana Department of Environmental Quality Office of Environmental ComplianceSurveillance Division Ji.Wiley@LA.gov to W3F1-2015-0079Facility Operating License No. NPF MarkupThis attachment contains 2 pages. (a) The first performance of SR 6.5.17, in accordance withSpecification 6.5.17.c.(i), shall be within the specified Frequencyof 6 years, plus the 18-month allowance of SR 4.0.2, as measuredfrom April 17, 2004, the date of the most recent successful tracergas test, as stated in the October 8, 2004 letter response toGeneric Letter 2003-01, or within the next 18 months if the timeperiod since the most recent successful tracer gas test is greater than 6 years.(b) The first performance of the periodic assessment of CREhabitability, Specification 6.5.17.c.(ii), shall be within 3 years, plusthe 9-month allowance of SR 4.0.2, as measured from April 17,2004, the date of the most recent successful tracer gas test, asstated in the October 8, 2004 letter response to Generic Letter2003-01, or within the next 9 months if the time period since themost recent successful tracer gas test is greater than 3 years.(c)The first performance of the periodic measurement of CREpressure, Specification 6.5.17.d, shall be within 18 months, plusthe 138 days allowed by SR 4.0.2, as measured from August 13,2008, the date of the most recent successful pressuremeasurement 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 andJ to 10 CFR Part 50. These exemptions are described in the Office of NuclearReactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptionsare authorized by law and will not endanger life or property or the commondefense and security and are otherwise in the public interest. These exemptionsare, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting ofthese exemptions, the facility will operate, to the extent authorized herein, inconformity with the application, as amended, the provisions of the Act, and therules and regulations of the Commission.AMENDMENT NO. 171, 218, 234, 239, 241 , XXXRevised by letter dated July 26, 2007 Add Paragraph E moved to next page. E.EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguardscontingency plans including amendments made pursuant to provisions of theMiscellaneous Amendments and Search Requirements revisions to 10 CFR73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and10 CFR 50.54(p). The plan, which contains Safeguards Information protectedunder 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency andTraining & 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 theauthority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved byLicense Amendment No. 234 and supplemented by a change approved byAmendment No. 239 and 241.

F.Except as otherwise provided in the Technical Specifications or theEnvironmental Protection Plan, EOI shall report any violations of therequirements 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 Centervia the Emergency Notification System with written follow-up within 30 days inaccordance 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 typeand in such amounts as the Commission shall require in accordance withSection 170 of the Atomic Energy Act of 1954, as amended, to cover publicliability claims.

H.This license is effective as the date of issuance and shall expire at midnight onDecember 18, 2024.FOR THE NUCLEAR REGULATORYCOMMISSIONoriginal signed by H.R. DentonHarold R. Denton, DirectorOffice of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)2. Attachment 23. Appendix A (Technical Specifications) (NUREG-1117)4. Appendix B (Environmental Protection Plan)5. Appendix C (Antitrust Conditions)Date of Issuance: March 16, 1985AMENDMENT NO.

218 , XXX Paragraph E moved from previous page. to W3F1-2015-0079Facility Operating License No. NPF Clean CopyThis attachment contains 2 pages. (a) The first performance of SR 6.5.17, in accordance withSpecification 6.5.17.c.(i), shall be within the specified Frequencyof 6 years, plus the 18-month allowance of SR 4.0.2, as measuredfrom April 17, 2004, the date of the most recent successful tracergas test, as stated in the October 8, 2004 letter response toGeneric Letter 2003-01, or within the next 18 months if the timeperiod since the most recent successful tracer gas test is greater than 6 years.(b) The first performance of the periodic assessment of CREhabitability, Specification 6.5.17.c.(ii), shall be within 3 years, plusthe 9-month allowance of SR 4.0.2, as measured from April 17,2004, the date of the most recent successful tracer gas test, asstated in the October 8, 2004 letter response to Generic Letter2003-01, or within the next 9 months if the time period since themost recent successful tracer gas test is greater than 3 years.(c)The first performance of the periodic measurement of CREpressure, Specification 6.5.17.d, shall be within 18 months, plusthe 138 days allowed by SR 4.0.2, as measured from August 13,2008, the date of the most recent successful pressuremeasurement 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 andJ to 10 CFR Part 50. These exemptions are described in the Office of NuclearReactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptionsare authorized by law and will not endanger life or property or the commondefense and security and are otherwise in the public interest. These exemptionsare, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting ofthese exemptions, the facility will operate, to the extent authorized herein, inconformity with the application, as amended, the provisions of the Act, and therules and regulations of the Commission.AMENDMENT NO. 171, 218, 234, 239, 241 , XXXRevised 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 safeguardscontingency plans including amendments made pursuant to provisions of theMiscellaneous Amendments and Search Requirements revisions to 10 CFR73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and10 CFR 50.54(p). The plan, which contains Safeguards Information protectedunder 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency andTraining & 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 theauthority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved byLicense Amendment No. 234 and supplemented by a change approved byAmendment No. 239 and 241.

F.Except as otherwise provided in the Technical Specifications or theEnvironmental Protection Plan, EOI shall report any violations of therequirements 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 Centervia the Emergency Notification System with written follow-up within 30 days inaccordance 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 typeand in such amounts as the Commission shall require in accordance withSection 170 of the Atomic Energy Act of 1954, as amended, to cover publicliability claims.

H.This license is effective as the date of issuance and shall expire at midnight onDecember 18, 2024.FOR THE NUCLEAR REGULATORYCOMMISSIONoriginal signed by H.R. DentonHarold R. Denton, DirectorOffice of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)2. Attachment 23. Appendix A (Technical Specifications) (NUREG-1117)4. Appendix B (Environmental Protection Plan)5. Appendix C (Antitrust Conditions)Date of Issuance: March 16, 1985AMENDMENT NO.

218 , XXX to W3F1-2015-0079 Waterford 3 Updated Final Safety Analysis Report - MarkupThis attachment contains 1 page.

WSES-FSAR-UNIT-3 TABLE 15.0-5CHAPTER 15 AVERAGE CONTROL ELEMENT ASSEMBLY (CEA) INSERTION TIMES Average CEA Insertion(%)Time (Seconds)0 0.00 0 0.60 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 Add s W3F1-2015-0079 October 8, 2015U.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 ReviseControl Element Drop Times, July 2, 2015 [ADAMS Accession Number ML15197A106].2. W3F1-2015-0061, Supplement to Revise Control ElementAssembly Drop Times Associated with TechnicalSpecification 3.1.3.4, August 13, 2015 [ADAMS Accession Number ML15226A346].3. NRC CEA Drop Time Submittal Request for AdditionalInformation, August 26, 2015 [ADAMS Accession Number ML15232A275].4. W3F1-2015-0062, Control Element Assembly Drop TimesSubmittal Request for Additional Information, September 23, 2015.

Dear Sir or Madam:

On July 2, 2015, Entergy Operations, Inc. (Entergy) requested an amendment to revise theControl Element Assembly (CEA) drop times associated with Technical Specification3.1.3.4 for Waterford Steam Electric Station Unit 3 (Waterford 3) [Reference 1]. On August13, 2015, Waterford 3 submitted a supplement [Reference 2] to provide additional accidentscenario results to bound a possible increase in the control element assembly holding coildecay time. The Nuclear Regulatory Commission (NRC) requested additional informationto 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 fourcommitments. After further discussions with the NRC, Waterford 3 is requesting that thesecond commitment be modified and changed to a license condition.Entergy Operations, Inc.

17265 River Road Killona, LA 70057Tel 504 739 6660Fax 504 739 6678 Michael R. ChisumSite Vice President Waterford 3 W3F1-2015-0079 Page 2Attachment 1 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 theFacility Operating License No. NPF-38 change. Attachment 3 contains the Waterford 3Updated Final Safety Analysis Report (UFSAR) markup of the new CEA drop time table.This submittal does not alter the no significant hazards consideration or environmentalassessment 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 Markup2. Facility Operating License No. NPF Clean Copy3. Waterford 3 Updated Final Safety Analysis Report - Markupcc: 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 3Michael.Orenak@nrc.gov Louisiana Department of Environmental Quality Office of Environmental ComplianceSurveillance Division Ji.Wiley@LA.gov to W3F1-2015-0079Facility Operating License No. NPF MarkupThis attachment contains 2 pages. (a) The first performance of SR 6.5.17, in accordance withSpecification 6.5.17.c.(i), shall be within the specified Frequencyof 6 years, plus the 18-month allowance of SR 4.0.2, as measuredfrom April 17, 2004, the date of the most recent successful tracergas test, as stated in the October 8, 2004 letter response toGeneric Letter 2003-01, or within the next 18 months if the timeperiod since the most recent successful tracer gas test is greater than 6 years.(b) The first performance of the periodic assessment of CREhabitability, Specification 6.5.17.c.(ii), shall be within 3 years, plusthe 9-month allowance of SR 4.0.2, as measured from April 17,2004, the date of the most recent successful tracer gas test, asstated in the October 8, 2004 letter response to Generic Letter2003-01, or within the next 9 months if the time period since themost recent successful tracer gas test is greater than 3 years.(c)The first performance of the periodic measurement of CREpressure, Specification 6.5.17.d, shall be within 18 months, plusthe 138 days allowed by SR 4.0.2, as measured from August 13,2008, the date of the most recent successful pressuremeasurement 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 andJ to 10 CFR Part 50. These exemptions are described in the Office of NuclearReactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptionsare authorized by law and will not endanger life or property or the commondefense and security and are otherwise in the public interest. These exemptionsare, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting ofthese exemptions, the facility will operate, to the extent authorized herein, inconformity with the application, as amended, the provisions of the Act, and therules and regulations of the Commission.AMENDMENT NO. 171, 218, 234, 239, 241 , XXXRevised by letter dated July 26, 2007 Add Paragraph E moved to next page. E.EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguardscontingency plans including amendments made pursuant to provisions of theMiscellaneous Amendments and Search Requirements revisions to 10 CFR73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and10 CFR 50.54(p). The plan, which contains Safeguards Information protectedunder 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency andTraining & 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 theauthority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved byLicense Amendment No. 234 and supplemented by a change approved byAmendment No. 239 and 241.

F.Except as otherwise provided in the Technical Specifications or theEnvironmental Protection Plan, EOI shall report any violations of therequirements 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 Centervia the Emergency Notification System with written follow-up within 30 days inaccordance 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 typeand in such amounts as the Commission shall require in accordance withSection 170 of the Atomic Energy Act of 1954, as amended, to cover publicliability claims.

H.This license is effective as the date of issuance and shall expire at midnight onDecember 18, 2024.FOR THE NUCLEAR REGULATORYCOMMISSIONoriginal signed by H.R. DentonHarold R. Denton, DirectorOffice of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)2. Attachment 23. Appendix A (Technical Specifications) (NUREG-1117)4. Appendix B (Environmental Protection Plan)5. Appendix C (Antitrust Conditions)Date of Issuance: March 16, 1985AMENDMENT NO.

218 , XXX Paragraph E moved from previous page. to W3F1-2015-0079Facility Operating License No. NPF Clean CopyThis attachment contains 2 pages. (a) The first performance of SR 6.5.17, in accordance withSpecification 6.5.17.c.(i), shall be within the specified Frequencyof 6 years, plus the 18-month allowance of SR 4.0.2, as measuredfrom April 17, 2004, the date of the most recent successful tracergas test, as stated in the October 8, 2004 letter response toGeneric Letter 2003-01, or within the next 18 months if the timeperiod since the most recent successful tracer gas test is greater than 6 years.(b) The first performance of the periodic assessment of CREhabitability, Specification 6.5.17.c.(ii), shall be within 3 years, plusthe 9-month allowance of SR 4.0.2, as measured from April 17,2004, the date of the most recent successful tracer gas test, asstated in the October 8, 2004 letter response to Generic Letter2003-01, or within the next 9 months if the time period since themost recent successful tracer gas test is greater than 3 years.(c)The first performance of the periodic measurement of CREpressure, Specification 6.5.17.d, shall be within 18 months, plusthe 138 days allowed by SR 4.0.2, as measured from August 13,2008, the date of the most recent successful pressuremeasurement 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 andJ to 10 CFR Part 50. These exemptions are described in the Office of NuclearReactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptionsare authorized by law and will not endanger life or property or the commondefense and security and are otherwise in the public interest. These exemptionsare, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting ofthese exemptions, the facility will operate, to the extent authorized herein, inconformity with the application, as amended, the provisions of the Act, and therules and regulations of the Commission.AMENDMENT NO. 171, 218, 234, 239, 241 , XXXRevised 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 safeguardscontingency plans including amendments made pursuant to provisions of theMiscellaneous Amendments and Search Requirements revisions to 10 CFR73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and10 CFR 50.54(p). The plan, which contains Safeguards Information protectedunder 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency andTraining & 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 theauthority of 10 CFR 50.90 and 10 CFR 50.54(p). The EOI CSP was approved byLicense Amendment No. 234 and supplemented by a change approved byAmendment No. 239 and 241.

F.Except as otherwise provided in the Technical Specifications or theEnvironmental Protection Plan, EOI shall report any violations of therequirements 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 Centervia the Emergency Notification System with written follow-up within 30 days inaccordance 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 typeand in such amounts as the Commission shall require in accordance withSection 170 of the Atomic Energy Act of 1954, as amended, to cover publicliability claims.

H.This license is effective as the date of issuance and shall expire at midnight onDecember 18, 2024.FOR THE NUCLEAR REGULATORYCOMMISSIONoriginal signed by H.R. DentonHarold R. Denton, DirectorOffice of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)2. Attachment 23. Appendix A (Technical Specifications) (NUREG-1117)4. Appendix B (Environmental Protection Plan)5. Appendix C (Antitrust Conditions)Date of Issuance: March 16, 1985AMENDMENT NO.

218 , XXX to W3F1-2015-0079 Waterford 3 Updated Final Safety Analysis Report - MarkupThis attachment contains 1 page.

WSES-FSAR-UNIT-3 TABLE 15.0-5CHAPTER 15 AVERAGE CONTROL ELEMENT ASSEMBLY (CEA) INSERTION TIMES Average CEA Insertion(%)Time (Seconds)0 0.00 0 0.60 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 Add