ML053480192
| ML053480192 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/06/2005 |
| From: | Balduzzi M Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2.05.065, 2.05.085, TAC MC7055 | |
| Download: ML053480192 (4) | |
Text
WI Entergy Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 December 6, 2005 Michael A. Balduzzi Site Vice President U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Docket 50-293 License No. DPR-35 Response to NRC Request for Additional Information, License Amendment Request for Rod Worth Minimizer Bypass Allowances (TAC No. MC7055)
REFERENCE:
- 1. Entergy Letter, 2.05.006, License Amendment Request, Rod Worth Minimizer Bypass Allowances, dated May 24, 2005.
- 2. NRC Letter, 1.05.121, Request for Additional Information Regarding Technical Specification Changes for the Rod Worth Minimizer (TAC No. MC7055), dated October 28, 2005.
LETTER NUMBER: 2.05.085
Dear Sir or Madam:
By Reference 2, the NRC requested additional information to support review of Entergy's request to revise Pilgrim Station Technical Specifications for the Rod Worth Minimizer. Entergy has evaluated the request and the response is provided in Attachment 1.
This response does not invalidate the no significant hazard conclusions previously submitted in Reference 1. This letter contains no commitments.
If you have any questions or require additional information, please contact Mr. Bryan Ford, Licensing Manager, at (508) 830-8403.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the day of December 2005.
6 th Sincerely, icha . Bal uzzi Site Vice President ERS/dm
Attachment:
- 1. Entergy response to NRC Request for Additional Information regarding Technical Specification changes for the Rod Worth Minimizer (TAC No. MC7055).
Entergy Nuclear Operations, Inc Letter 2.05.085 Pilgrim Nuclear Station Page 2 cc: Mr. James Shea, Project Manager Mr. Robert Walker Office of Nuclear Reactor Regulation Radiation Control Program Mail Stop: 0-8B-1 Commonwealth of Massachusetts U.S. Nuclear Regulatory Commission 90 Washington Street 1 White Flint North Dorchester, MA 02121 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Ms. Christine McCombs, Director Region 1 Mass. Emergency Management Agency 475 Allendale Road 400 Worcester Road King of Prussia, PA 19406 P.O. Box 1496 Framingham, MA 01702 Senior Resident Inspector Pilgrim Nuclear Power Station
7.
Attachment 1 Entergy Response to NRC RAls Regarding Technical Specification Changes for the Rod Worth Minimizer (TAC No. MC7055)
RAI 1: Your May 24, 2005 submittal did not include clean copies of the proposed technical specification (TS) pages. Please provide clean pages of the revised TS pages.
Response: Consistent with normal practice, the proposed revised pages were not included in the application. Revised pages were provided to the NRR Project Manager by email in mid-September, 2005.
RAI 2: You propose to change words in TS 3.3.F.A.2.1 from "12 months" to "calendar year." What is the functional difference between "12 months" and a "calendar year"?
Provide an example of how the RWM not being inoperable in the last 12 months is different from it not being inoperable in the last calendar year.
Response: This change is made to be consistent with the wording recommended in improved standard technical specifications (ITS) NUREG-1433, Rev. 3, LCO 3.3.2.1, Required Actions for Condition C. The only difference is that the use of "Calendar year' does not always guarantee a minimum of 12 months between startups with an inoperable Rod Worth Minimizer (RWM) i.e., the use of "calendar year" could allow two different startups with an inoperable RWM to occur in two different calendar years but less than 12 months apart. Nonetheless, the use of either "12 months" or "Calendar year" will allow no more than one startup with an inoperable RWM per year.
The purpose of the "12 month" or "calendar year" restriction is to help ensure the RWM is maintained OPERABLE as much as possible. There is no reduction in safety because as stated in the application, Pilgrim will continue to administratively control the startup with an inoperable RWM in accordance with current TS 3.3.F Action A.2.2 'Verify movement of control rods is in compliance with BPWS by a second licensed operator or other qualified member of the technical staff during control rod movement." This is an approved method of ensuring the rod movement sequences of the BPWS are enforced when the RWM is not available. The second individual verifying the rod movements are in compliance with the BPWS is performing the same action that the RWM performs (i.e., provides protection against a single operator error). Furthermore, the use of a second licensed operator to verify all control rod movements is not a burden or off-normal performance requirement for the operating staff because this is normal practice for all control rod movements, with the exception of off-normal and transient conditions. Other examples of the use of "Calendar Year" are contained in license amendments approved by the NRC going back as far as 1989 for Limerick Unit 1 dated March 22, 1989 (TAC 71584) and Hatch Nuclear Plant Units 1 & 2, dated May 20,1992 (TAC M8191 1 and M81912).
RAI 3: Previously your TS required that if the RWM failed during startup that you must immediately suspend control rod movement except by scram. However you were allowed to move rods in compliance with banked position withdrawal sequences (BPWS) by using verification from a second licensed operator or other qualified member of the technical staff as long as startup with the RWM inoperable has not been performed in the last 12 months. Your proposed TS no longer requires the restriction that startup with RWM inoperable has not been performed in the last 12 months. Your proposed TS would allow you to move rods in compliance with BPWS with the RWM inoperable as long as 12 or more rods have been withdrawn. Provide a technical basis explaining how no longer requiring the restriction that startup with RWM inoperable has not been performed in the last 12 months does not adversely impact safety.
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Response: As discussed in the response to RAI 2, the proposal changes the "12 month" restriction to a "calendar year" restriction and provides an additional option to allow control rod withdrawal (startup) to continue if the RWM becomes inoperable after at least 12 control rods have been withdrawn while the RWM was OPERABLE (i.e., RWM was OPERABLE when startup commenced). This is consistent with the ITS Required Actions for Condition C under LCO 3.3.2.1. The option to continue startup under these conditions provides operational flexibility without a reduction in safety should the RWM suddenly become inoperable during the startup. The proposed changes continue to require the RWM to be OPERABLE at the beginning of each startup, with only one exception per calendar year. The proposed change eliminates the penalty (startup may not continue) that would otherwise be imposed if the RWM was OPERABLE when startup commenced but suddenly became inoperable during the startup and the RWM had been inoperable during a prior startup within the last year. Verifying > 12 control rods withdrawn prior to continuing startup with the RWM inoperable is intended to demonstrate that the RWM was OPERABLE when Startup began and is in keeping with the philosophy of maintaining the RWM OPERABLE as much as possible.
Under the proposed specifications, to determine if startup may continue, the Operator would determine if one of two conditions is satisfied: either verify that a startup with an inoperable RWM has not been performed within the last calendar year OR verify that at least 12 control rods have been withdrawn during the current startup prior to the RWM being declared inoperable. If at least one of these two options is satisfied, startup may proceed provided that control rod movements are verified to be in compliance with the BPWS by a second licensed operator or other qualified member of the technical staff.
This is an approved method of ensuring the rod movement sequences of the BPWS are enforced when the RWM is not available. The second individual verifying the rod movements are in compliance with the BPWS is performing the same action that the RWM performs (i.e., provides protection against a single operator error).
These requirements that limit startup activities were developed to satisfy the NRC's expectations that licensees improve the operability/reliability of the RWM to minimize startups with an inoperable RWM that instead rely on a second licensed operator to verify control rod patterns comply with the BPWS. The genesis of these requirements is documented in a letter from the NRC (Thadani) to GE (Charnley) dated December 27, 1987 that is in response to the submittal of Amendment 17 to GE Licensing Topical Report NEDE-2401 1-P-A (GESTAR II) transmitted in a letter to the NRC from the BWROG dated August 15,1986.
The proposed changes are consistent with the wording recommended in ITS NUREG-1433, Rev. 3 in LCO 3.3.2.1 Condition C, Action C.2.1.1 and C.2.1.2. Other examples of the use of this option are contained in license amendments approved by the NRC going back as far as 1989 for Limerick Unit 1 dated March 22, 1989 (TAC 71584) and Hatch Nuclear Plant Units 1 &2, dated May 20,1992 (TAC M81911 and M81912). The NRC has acknowledged that the use of the proposed option is acceptable, improves operational flexibility and unit availability, reduces undue restrictions on startup activities and does not reduce safety.
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