Text

License Amendment Request to Adopt TSTF-460, Revision 0, Control Rod Scram Times.
	ML093430242
Person / Time
Site:	Hope Creek
Issue date:	12/01/2009
From:	Jamila Perry; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LAR H09-06, LR-N09-235
	Download: ML093430242 (37)
	v • d • e

PSEG Nuclear LLC P.O. Box 236,, Hancocks Bridge, NJ 08038-0236 0 PSEG DEC 012009 NuclearL.L. C.

10 CFR 50.90 LR-N09-235 LAR H09-06 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

LICENSE AMENDMENT REQUEST TO ADOPT TSTF-460, REVISION 0, "CONTROL ROD SCRAM TIMES" In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations, PSEG Nuclear, LLC (PSEG) requests an amendment to the facility operating license listed for Hope Creek Generating Station (HCGS).

The proposed amendment would revise Technical Specification (TS) testing frequency for the surveillance requirement (SR) in existing TS 3.1.3.2, "Control Rod Maximum Scram Insertion Times." These changes are based on TS Task Force (TSTF) change traveler TSTF-460 (Revision 0) that has been approved generically for the boiling water reactor (BWR) Standard TS, NUREG-1433 (BWR/4) and NUREG-1434 (BWR/6) by revising the frequency of STS SR 3.1.4.2, control rod scram time testing, from "at least once per 120 days of POWER OPERATION" to "at least once per 200 days of POWER OPERATION." A notice announcing the availability of this proposed TS change using the Consolidated Line Item Improvement Process was published in the Federal Reqister on August 23, 2004 (69 FR 51854).

Additionally, because Hope Creek has not implemented NUREG-1433, Rev. 3, "Standard Technical Specifications (STS), General Electric Plant, BWR/4", PSEG is proposing variations from the CLIIP to ensure consistency with STS. These proposed variations align HCGS TS with STS to allow for a direct use of TSTF-460 and justify the increased surveillance interval. The changes to align with STS involve the adoption of a revised control rod scram time test evaluation methodology and an establishment of a category of "slow" rods. provides a description of the proposed change, with modifications to the NRC model application published for TSTF-460. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides the marked up TS bases pages for information only. Attachment 4 contains the regulatory commitments made in this submittal.

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Document Control Desk Page 2 LR-N09-235 PSEG requests approval of the proposed license amendment by December 01, 2010 with implementation within 60 days of receipt of the approved amendment. In accordance with the requirements of 10 CFR 50.91 (b) (1), a copy of this request for amendment has been sent to the State of New Jersey.

If you have any questions or require additional information, please contact Mr. Jeff Keenan at (856) 339-5429.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 1 (bate)

Sincerely, John F. Perry Site Vice Preside Hope Creek Generating Station Attachments (4)

S. Collins, Regional Administrator - NRC Region I R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector - Hope Creek P. Mulligan, Manager IV, NJBNE Commitment Coordinator - Hope Creek PSEG Commitment Coordinator - Corporate

Document Control Desk Page 3 LR-N09-235 (The bcc list should not be submitted as partof the DCD submittal - remove this page priorto submittal and make the bcc distribution accordingly)

President and Chief Nuclear Officer Nuclear Senior Vice President - Hope Creek Vice President, Operations Support Director - Nuclear Oversight Director - Regulatory Affairs Plant Manager - Hope Creek Regulatory Assurance Manager - Hope Creek Licensing Manager Document Control

ATTACHMENT 1 LAR H09-06 LR-N09-235 ATTACHMENT 1 LICENSE AMENDMENT REQUEST TO ADOPT TSTF-460, REVISION 0, "CONTROL ROD SCRAM TIMES" EVALUATION OF PROPOSED AMENDMENT TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 PROPOSED CHANGE

S

3.0 BACKGROUND

4.0 REGULATORY REQUIREMENTS

5.0 TECHNICAL ANALYSIS

6.0 COMMITMENTS 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION

8.0 ENVIRONMENTAL CONSIDERATION

9.0 PRECEDENT

10.0 REFERENCES

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ATTACHMENT 1 LAR H09-06 LR-N09-235

1.0 INTRODUCTION

The proposed license amendment revises the required testing frequency for the surveillance requirement (SR) in existing Technical Specification (TS) 3.1.3.2, "Control Rod Maximum Scram Insertion Times." A notice announcing the availability of this proposed TS change using the consolidated line item improvement process (CLIIP) was published in the Federal Register on August 23, 2004 (69 FR 51854).

The primary purpose of the proposed change is to revise TS 3/4.1.3.2 to increase required control rod scram time test frequency interval from "at least once per 120 days of POWER OPERATION" to "at least once per 200 days of POWER OPERATION." This change is consistent with the Consolidated Line Item Improvement Process Notice of Availability published on August 23, 2004 [69 FR 51864] and the Technical Specification Task Force Change Traveler, TSTF-460, Rev 0.

Additionally, because Hope Creek has not implemented NUREG-1433, Rev. 3, "Standard Technical Specifications (STS), General Electric Plant, BWR/4", PSEG is proposing variations from the CLIIP to ensure consistency with STS. The STS format changes involve adoption of a revised control rod scram time test evaluation methodology. The proposed scram time test criterion 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.

Based on the establishment of operable but "slow" control rods, separation criteria for "stuck" control rods and requirements for control rod scram accumulator testing also need to be revised. The proposed changes to those TS are consistent with STS 3.1.3 and 3.1.5.

2.0 PROPOSED CHANGE

S These changes are based on TS Task Force (TSTF) change traveler TSTF-460 (Revision 0) that has been approved generically for the boiling water reactor (BWR)

Standard TS, NUREG-1433 (BWR/4) and NUREG-1434 (BWR/6). PSEG is proposing the following changes:

1) TS LCO 3.1.3.1 - Control Rod Operability TS LCO 3.1.3.1 Action A.1 .a is being revised to require that with one withdrawn control rod stuck, verify stuck control rod separation criteria are met as defined in the Bases.

The time requirement is revised from "Within one hour" to "immediately". Consistent with STS, HCGS will consider "immediately" to mean "the Required Action should be pursued without delay and in a controlled manner. This change is required due to revision of TS 3/4.1.3.3 which allows control rods to be "slow" but operable. TS Bases for 3.1.3.1 Action A. 1 are also being revised to specifically identify "stuck" rod separation criteria as 2of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 it applies to "slow" but operable control rods. This change is consistent with the LCO requirements defined in STS 3.1.3.A and 3.1.3.B.

Existing TS LCO 3.1.3.1 Action A.1.b is moved to the proposed TS LCO 3.1.3.1 Action A.2, with a new time requirement of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months instead of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This allows for more time to complete the required action and aligns with STS. The action is simplified to state "disarm the associated control rod drive" to further align with STS. The Bases will describe the actions to take to disarm the drive. This change is consistently applied throughout proposed TS 3.1.3 wherever the required action is to disarm the control rod drive.

Existing TS LCO 3.1.3.1 Action A.2 is removed with the proposed changes. This action is not found in STS. HCGS is requesting this change to further align with STS.

TS LCO 3.1.3.1 Action B.1 is revised to remove the option of operating with an inoperable control rod(s) in the withdrawn position. The action now requires that the inoperable control rod(s) be fully inserted within three hours and disarmed either electrically or hydraulically within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This change is consistent with the LCO requirements defined in STS 3.1.3.C.

New Actions are added to TS LCO 3.1.3.1 to address the effect of inoperable rods on the Control Rod Drop Accident (CRDA) and the Banked Position Withdrawal Sequence (BPWS). New Action C addresses the separation criteria of inoperable rods that was removed from proposed Actions A.1 and B.1 described above. New Action D addresses the maximum allowed inoperable rods within a BPWS group. Because of the addition of these two Actions, existing Actions C through E are relabeled E through G.

2) TS 3/4.1.3.2 - Control Rod Maximum Scram Insertion Times TS LCO 3.1.3.2 is being revised to delete Action A.2 to be consistent with STS 3.1.3.

There is no such requirement in STS 3.1.3 to perform existing SR 4.1.3.2.c at an increased frequency with three or more control rods with maximum scram insertion times in excess of 7.0 seconds.

3) SR 4.1.3.2 TS SR 4.1.3.2 is being revised to state "Verify each control rod scram time from fully withdrawn to notch position 05 is < 7.0 seconds in accordance with Surveillance Requirement 4.1.3.3." Existing TS SR 4.1.3.2 is then relocated to proposed TS SR 4.1.3.3 and modified to align with STS 3.1.4. Included in this change is to modify the required reactor coolant pressure for the surveillance from greater than or equal to 950 psig to greater than or equal to 800 psig. The SR is also modified to state "reactor steam dome pressure" instead of "reactor coolant pressure" to better describe the parameter that is measured. Existing TS SR 4.1.3.2.a and 4.1.3.2.b are being revised to change surveillance test criteria for scram time testing. The existing surveillances address scram time test requirements following Refueling Outages, Shutdowns greater than 120 days, and at-power tests within each 120 days of operation.

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ATTACHMENT 1 LAR H09-06 LR-N09-235

4) TS 3/4.1.3.3- Control Rod Scram Insertion Times TS LCO 3.1.3.3 is being revised and LCO 3.1.3.4 is being deleted to change the control rod scram insertion test requirements. This revision deletes the requirements for addressing average scram times for all operable rods and average scram times for the three fastest operable control rods in each group of four control rods in all two-by-two arrays. The proposed LCO identifies new scram time acceptance criteria for individual control rods. New TS Table 3.1.3.3-1, Control Rod Scram Times, is provided to identify scram test configuration requirements and associated acceptance criteria. Based on this table, criteria for determining "slow" and "inoperable" control rods are defined.

These changes are consistent with the LCO requirements defined in STS 3.1.4.

5) SR4.1.3.3 The proposed surveillances (TS SR 4.1.3.3.a through .d) rely on new TS Table 3.1.3.3-1 to control test configurations and test acceptance criteria. Proposed TS SR 4.1.3.3.b extends the at-power scram time test frequency from "at least once per 120 days of POWER OPERATION" to "at least once per 200 days of POWER OPERATION." These changes are consistent with STS 3.1.4 and NRC approved Technical Specifications Change Traveler TSTF-460, Rev. 0.

6) TS 3/4.1.3.5- Control Rod Scram Accumulators TS 3/4.1.3.5 Action A.1.b and Action A.2.b are being revised to address the option for declaring control rods associated with inoperable accumulators, either "slow" or "inoperable." The revised LCO actions address contingencies for one inoperable accumulator with reactor steam dome pressure > 900 psig, and two or more inoperable accumulators with reactor steam dome pressure > 900 psig. These changes are consistent with STS 3.1.5.

3.0 BACKGROUND

The background for this application is adequately addressed by the CLIIP Notice of Availability published on August 23, 2004 (69 FR 51854) and TSTF-460.

The Preface of NUREG-1433, Revision 3, "Standard Technical Specifications General Regulations General Electric Plants, BWR/4" licensees are encouraged to upgrade their technical specifications to be "consistent with those criteria and conforming, to the practical extent, to Revision 3 to the improved STS." Because Hope Creek has not adopted the improved Standard Technical Specifications (NUREG 1433), PSEG is proposing variations from the TS changes described in TSTF-460. These proposed variations align HCGS TS with STS to allow for a direct use of TSTF-460 to justify the increased surveillance interval. The changes to align with STS involve the adoption of a revised control rod scram time test evaluation methodology and an establishment of category of "slow" rods. These changes do not alter or change the technical intent of the proposed changes. This proposed Technical Specification change request is consistent, where applicable, with Standard Technical Specifications.

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ATTACHMENT 1 LAR H09-06 LR-N09-235 4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the CLIIP Notice of Availability published on August 23, 2004 (69 FR 51854) and TSTF-460.

5.0 TECHNICAL ANALYSIS

PSEG has reviewed the safety evaluation (SE) published on August 23, 2004 (69 FIR 51854) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE and the supporting information provided to support TSTF-460.

PSEG has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Hope Creek Generating Station (HCGS) and justify this amendment for the incorporation of the changes to the HCGS TS.

However, PSEG is proposing additional changes to ensure consistency with NUREG-1433, Rev 3, "Standard Technical Specifications (STS), General Electric Plant, BWRP4" (Reference 2), The proposed changes revise the LCO, SRs and Bases associated with Control Rod Operability (TS 3/4.1.3.1), Control Rod Scram Insertion Times (TS 3/4.1.3.2, TS 3/4.1.3.3 and TS 3/4.1.3.4), and Control Rod Accumulator (TS 3/4.1.3.5) to be consistent with STS 3.1.3, 3.1.4, and 3.1.5. These changes are described below.

5.1 TS 3/4.1.3.1 - Control Rod Operability Existing TS LCO 3.1.3.1, Action A.1 .a ensured that a stuck control rod, if withdrawn, was verified to be "separated from all other inoperable control rods by at least two control cells in all directions". The purpose of the Action was to verify scram reactivity requirements were not adversely affected and that the requirements of the CRDA analysis were met. With the introduction of "slow" but operable control rods in proposed TS 3.1.3.3, this LCO and stuck control rod separation criteria required revision to address the scram reactivity requirements. The CRDA requirements are now addressed through the proposed LCOs 3.1.3.1.c and 3.1.3.1.d described below.

The proposed LCO requires operators to "verify stuck control rod separation criteria are met immediately," and the proposed TS Bases identifies stuck rod separation criteria.

The revised bases indicates that stuck rod separation criteria are not met if: a) the stuck control rod occupies a location adjacent to two "slow" control rods; b) the stuck control rod occupies a location adjacent to one "slow" control rod, and the one "slow" control rod is also adjacent to another "slow" control rod; or, c) if the stuck control rod occupies a location adjacent to one "slow" control rod when there is another pair of "slow" control rods adjacent to one another. "Slow" control rods are defined using proposed TS Table 3.1.3.3-1. These changes are consistent'with LCO requirements and TS Bases defined in STS 3.1.3 and 3.1.4. The above referenced TS LCO and Bases changes ensure the distribution and performance of control rods meet the local scram reactivity rate assumptions used in safety analyses in the event of a design basis accident or transient.

Existing TS LCO 3.1.3.1 Action A.1.b is moved to the proposed TS LCO 3.1.3.1 Action A.2, with a new time requirement of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months instead of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This allows for more time to complete the required action and aligns with STS. The allowed completion time of 2 5 of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 hours is acceptable, considering the reactor can still be shut down, assuming no additional control rods fail to insert, and provides a reasonable time to perform the required action in an orderly manner. The action is simplified to state "disarm the associated control rod drive" to further align with STS. The Bases will describe the actions to take to disarm the drive. This change is consistently applied throughout proposed TS 3.1.3 wherever the required action is to disarm the control rod drive.

Existing TS LCO 3.1.3.1 Action A.2 is removed with the proposed changes. This action is not found in STS. HCGS is requesting this change to further align with STS. To allow continued operation with a withdrawn control rod stuck, proposed TS LCO 3.1.3.1 Actions A.1 and A.2 must be met. In addition, the Shutdown Margin requirements of TS LCO 3.1.1 must be met. If all LCOs are met, then there is assurance that the scram reactivity requirements will be met and the unit can be shutdown should a Design Basis Accident (DBA) or transient require a shutdown. These LCOs are condition specific and not time-dependent. Therefore, the passage of time will not affect these condition specific requirements. If any of these LCOs are not met, each of these actions requires the unit be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Existing TS LCO 3.1.3.1, Action B. 1 ensured that inoperable but trippable control rod(s) were verified to be "separated from all other inoperable control rods by at least two control cells in all directions". The purpose of the Action was to verify scram reactivity requirements were not adversely affected and that the requirements of the CRDA analysis were met. The scram reactivity requirements could be adversely affected if a measured scram time to notch 05 for a control rod was greater than 7 seconds. Under the current requirements, continued operation is allowed with withdrawn control rods declared inoperable per TS 3.1.3.2 Action A.1. All other TS actions statements for inoperable control rods require that the rod be fully inserted and disarmed. The allowance to operate for extended periods of time with withdrawn inoperable control rods is not found in STS. Therefore, to align with STS, the proposed LCO 3.1.3.1, Action B.1 requires that the inoperable control rod(s) be fully inserted within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and disarmed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This change is conservative to the current HCGS requirements. This change also justifies the deletion of existing TS LCO 3.1.3.2 Action A.2, since control rods declared inoperable under TS LCO 3.1.3.2 Action A.1 will have to meet the proposed LCO 3.1.3.1, Action B.1 and be fully inserted within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Fully inserted control rods meet their design function and therefore do not require scram time testing on a more frequent basis. The CRDA requirements are now addressed through the proposed LCOs 3.1.3.1.c and 3.1.3.1.d described below.

New Actions are added to TS LCO 3.1.3.1 to address the effect of inoperable rods on the Control Rod Drop Accident (CRDA) and the Banked Position Withdrawal Sequence (BPWS). New Action C addresses the separation criteria of inoperable rods that was removed from proposed Actions A.1 and B.1 described above. New Action C further aligns the HCGS TS with STS by clarifying the options available to meet the requirements of the CRDA. PSEG is requesting the additional proposed Action C.3 to clarify that Actions C. 1 and C.2 need not be taken if an analysis is in place to demonstrate that all of the requirements of the CRDA are met. This will make such a requirement explicit in the TS instead of implicit, as was the previous practice.

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ATTACHMENT 1 LAR H09-06 LR-N09-235 New Action D addresses the maximum allowed inoperable rods within a BPWS group.

Proposed LCO 3.1.3.1 Actions C and D are modified by a note indicating that the Condition is not applicable when > 8.6% RTP, since the BPWS is not required to be followed under these conditions, as described in the Bases for LCO 3.1.4. Because of the addition of these two Actions, existing Actions C through E are relabeled E through G.

These changes will clarify and enforce the assumptions used in the CRDA in the HCGS TS. This LAR does not change any of these requirements or assumptions.

5.2 LCO 3.1.3.2 - Control Rod Maximum Scram Insertion Times TS LCO 3.1.3.2 is being revised to delete Action A.2 to be consistent with STS 3.1.3.

There is no such requirement in STS 3.1.3 to perform existing SR 4.1.3.2.c at an increased frequency with three or more control rods with maximum scram insertion times in excess of 7.0 seconds. Should this situation arise, these rods would already be declared inoperable and fully inserted and disarmed per the revised LCO 3.1.3.1 Action B.1 described above, thus satisfying their design function. In addition, with the proposed introduction of "slow" control rods being limited in number and required to be no more than 7.5% of the representative sample of control rods tested to verify continued performance of the scram function during the cycle, a generic degradation of scram performance should be found prior to relying on 3 or more control rods being inoperable with scram insertion times greater than 7 seconds.

5.3 SR 4.1.3.2 TS SR 4.1.3.2 is revised to align with STS SR 3.1.3.4. It is being revised to state "Verify each control rod scram time from fully withdrawn to notch position 05 is < 7.0 seconds in accordance with Surveillance Requirement 4.1.3.3." Existing TS SR 4.1.3.2 is then relocated to proposed TS SR 4.1.3.3 and revised to align with STS 3.1.4. These changes are justified because the requirement for a control rod to meet the 7.0 second time to notch 05 is unchanged. The situations (i.e. surveillances) when this requirement needs to be evaluated are essentially unchanged except as described below in Section 5.5.

5.4 TS 3/4.1.3.3 - Control Rod Scram Insertion Times The proposed changes to LCO 3.1.3.3 (not presented in TSTF-460, but are included in this submittal to align with STS) provide a different method to determine if the measured scram insertion times are sufficient to insert the amount of negative reactivity assumed in accident and transient analyses. A description and supporting analysis for the proposed test method (which is identical to that utilized by STS LCO 3.1.4) is contained in the Letter from R. F Janecek (BWROG) to R.W. Starostecki (NRC) "BWR Owners Group Revised Reactivity Control System Technical Specifications, "dated September 17, 1987 (Reference 2). The purpose of the control rod scram time LCO is to ensure the negative scram reactivity corresponding to that used in licensing basis calculations is supported by individual control rod drive scram performance distributions allowed by the Technical Specifications. Current TS LCOs 3.1.3.3 and 3.1.3.4 accomplish the above 7 of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 purpose by placing requirements on average scram times and local scram times (average of three fastest control rods in all groups of four control rods).

The methodology used in the design basis transient analysis (one-dimensional neutronics) assumes all control rods scram at the same speed. This is called the analytical scram time requirement. Performing an evaluation assuming all control rods scram at the analytical limit will result in the generation of a scram reactivity versus-time curve that is called the analytical scram reactivity curve. It is the purpose of the scram time LCO to ensure that under allowed plant conditions, this analytical scram reactivity will be met. Since scram reactivity cannot be readily measured at the plant, safety analyses use appropriately conservative scram reactivity-versus-insertion fraction curves to account for the variation in scram reactivity during a cycle. Therefore, the technical specifications must only ensure that the proposed scram times (in proposed Table 3.1.3.3-1) are satisfied.

If all control rods scram at least as fast as the proposed scram time limits, the analytical scram reactivity curve will be met. Proposed TS LCO 3.1.3.3 incorporates this philosophy by specifying scram time limits for each individual control rod instead of specifying limits for average scram times. Proposed TS LCO 3.1.3.1 Action A. l.a and TS LCO 3.1.3.3 scram time limits have margin to the analytical scram time limits to allow for a specified number and distribution of slow control rods, a single stuck control rod, and an assumed single failure. This is the same philosophy currently used for BWR/4*

plants that have converted to Standard Technical Specifications.

The scram times specified in proposed Table 3.1.3.3-1 reflect time measurements based on reed switch positions, which provide the control rod position indication. The reed switch closes ("pickup") when the index tube passes a specific location and then opens

("dropout") as the index tube travels upward. Verification of the specified scram times is accomplished through measurement of the "dropout" times. The scram times listed in proposed Table 3.1.3.3-1 reflect the required scram time values listed in Table 3.4 of the report provided with Reference 2 for those notch positions that are measured at HCGS.

These scram insertion times are consistent with the generic analytical scram reactivity rates identified for BWR/2-5 control rod drives.

Therefore, if all control rods meet the LCO scram time limits found in proposed TS Table 3.1.3.3-1, as measured from the de-energization of scram pilot valve solenoids at time zero, the analytical scram reactivity assumptions that will be credited in the cycle specific fuel limits analyses for HCGS will be satisfied. If any control rods do not meet the LCO time limit, the LCO specifies the allowed number and distribution of these "slow" but operable control rods to ensure the analytical scram reactivity assumptions are still satisfied.

If the number of "slow" rods is excessive (over -7% of 185, i.e., > 13) or do not meet stuck rod separation criteria, the unit must be shut down. This change is considered more restrictive on plant operation. Currently, the "average time" of all rods or a group of rods can be improved by a few fast scramming rods, even when there may be more than thirteen "slow" rods as defined in the proposed specification. Therefore, the proposed specification limits the number of "slow" rods to thirteen (13) and ensures no more than two (2) "slow" control rods occupy adjacent locations.

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ATTACHMENT 1 LAR H09-06 LR-N09-235 The proposed note to TS Table 3.1.3.3-1 (Note 2) ensures a control rod is not inadvertently considered "slow" when the scram time exceeds seven (7) seconds. This note references proposed TS SR 4.1.3.2. A footnote is added to Table 3.1.3.3-1 to state that "Scram times as a function of reactor steam dome pressure, when < 800 psig are within established limits." This allows for HCGS to meet the proposed SR 4.1.3.3.c for scram timing used to demonstrate operability of a control rod at reactor dome pressures less than 800 psig. These changes are consistent with STS 3.1.4. HCGS will commit to adding a requirement to the Technical Requirements Manual (TRM) to contain the required time limits for these types of scram time testing. HCGS will adopt the value of 2 seconds to notch 05 for a reactor steam dome pressure of 0 psig. This value is conservative to the limit listed in Table 3.1.4-1 in Reference 2, which specifies a 2 second limit to notch 06. Consistent with Reference 2, this limit of 2 seconds is acceptable to ensure that a control rod that meets the low pressure time requirement will also meet the high pressure time requirement. Linear interpolation will be used for reactor pressures between 0 and 800 psig using 2 seconds for 0 psig and 3.44 seconds for 800 psig (proposed Table 3.1.3.3-1.)

5.5 SR 4.1.3.3 TS SR 4.1.3.3 is revised to align with STS SRs 3.1.4.1 though 3.1.4.4. Proposed SRs 4.1.3.3.a, 4.1.3.3.b, and 4.1.3.3.d change the required reactor steam dome pressure from > 950 psig to > 800 psig. The proposed change to revise the required reactor pressure (> 800 psig vs. > 950 psig) encompasses a more conservative range because maximum scram insertion times occur at a reactor pressure of approximately 800 psig.

A reactor pressure of 800 psig corresponds to the limiting pressure for CRD scram testing for BWR/2-5 type systems. "Limiting" refers to the fact that the maximum scram insertion times will be experienced at this condition because of the competing effects of the reactor vessel pressure and the accumulator pressure scram forces. The primary scram insertion time requirements are related to transients from rated reactor pressure (assumed to be > 950 psig) and therefore, if the scram insertion times are demonstrated at pressures > 800 psig, then analytical scram reactivity requirements will be met.

Existing TS SR 4.1.3.2.a currently requires that all operable control rods be scram tested from the fully withdrawn position with the reactor pressure above 950 psig prior to exceeding 40% rated thermal power (RTP) following a refueling outage or an extended outage greater than 120 days. The requirements of this surveillance are to be addressed via revised TS SR 4.1.3.3.a, SR 4.1.3.3.c, and SR 4.1.3.3.d.

Proposed TS SR 4.1.3.3.a addresses the existing TS SR 4.1.3.2.a requirement to verify that each operable control rod scram time is within limits prior to reaching 40% RTP after each reactor shutdown > 120 days. The proposed surveillance is consistent with the existing surveillance and due to the reference to proposed TS Table 3.1.3.3-1, imposes a test criteria and restrictions (i.e., reactor pressure >_800 psig) consistent with STS, NUREG 1433.

Proposed TS SR 4.1.3.3.d addresses the existing TS SR 4.1.3.2.a requirement to verify each operable control rod scram time is within limits prior to reaching 40% RTP after each Refueling outage. The proposed surveillance will ensure each affected control rod 9 of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 scram time is within limits prior to reaching 40% RTP after fuel movement within the affected cell and after work on a control rod or CRD System that could affect scram time.

In addition, the proposed change to TS Bases 3/4.1.3.3 (for TS SR 4.1.3.3.d) identifies that for routine refueling outages, it is expected that all control rods will be affected.

Therefore, the proposed surveillance is consistent with the existing surveillance in that all potentially impacted control rods will be tested to ensure refueling outage work or on a control rod or CRD system did not adversely impact capability to scram the control rod.

Proposed TS SR 4.1.3.3.c imposes a new surveillance requirement to perform scram time testing on all control rods affected by control rod or CRD System work prior to declaring the rod(s) operable. Testing affected control rods is necessary to demonstrate the control rod is operable after CRD or CRD System work is performed. This test can be performed at any reactor pressure and since maintenance or modifications to control rods or the CRD System are typically performed when the reactor is shutdown, it is expected the affected rods be scram tested and operable prior to taking the reactor critical. This ensures that the affected rods are tested before they would potentially be required to scram (i.e., before going critical). This change is pursued to eliminate the requirement to declare affected control rods inoperable during reactor startup because of the inability (or impracticality) of performing a scram time test at > 950 psig as required by current TS.

Existing TS SR. 4.1.3.2.c addresses the requirements to perform scram time testing on a minimum of 10% of the CRDs "at least once per 120 days of POWER OPERATION."

Proposed TS SR 4.1.3.3.b ensures the "at-power" scram tests are performed on a representative sample of CRDs in accordance ,with the requirements of proposed TS Table 3.1.3.3-1. TS Bases have been revised to indicate a representative sample contains at least 10% of the control rods. This change is consistent with the requirements of STS 3.1.4.2.

In addition, the proposed TS SR 4.1.3.3.b extends the at-power scram time test frequency from "at least once per 120 days of POWER OPERATION" to "at least once per 200 days of POWER OPERATION." This increase in the duration between required tests is consistent with TSTF-460, Rev. 0 (Reference 1), which has been reviewed and approved generically by the NRC for the Boiling Water Reactor (BWR) STS, NUREG-1433 BWR/4 (Reference 2). As described in the CLIIP model SE, part of the justification for the change in surveillance frequency is the high reliability of the HCGS Control Rod Drive System. As requested in the CLIIP Notice of Availability published on August 23, 2004 [69 FR 51864], the historical performance of the Control Rod Drive System at HCGS is summarized below.

Hope Creek has demonstrated this high reliability of the scram function through review of historical scram time data. Scram time testing results from 1989 (Cycle 3) to early 2009 (Cycle 15) were reviewed. This data reflects a combined total of 5467 individual scram time tests, each measuring the scram time at four insertion positions (Positions 45, 39, 25, and 05). The review showed that all 5467 individual tests met the criterion of existing TS 3.1.3.2, namely "The maximum scram insertion time off each control rod from the fully withdrawn position to notch position 5, based on de-energization of the scram pilot solenoid valves as time zero, shall not exceed 7.0 seconds." The review 10 of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 also showed that Hope Creek has always met existing TS 3.1.3.3 for core average scram times.

Each performance of existing TS SR 4.1.3.2.c (every 120 days of POWER OPERATION) requires 10 percent of the control rods to be tested. This currently results in 4 (on the current 18-month cycle) mid-cycle tests within an operating cycle.

Therefore, over half of the control rods are not tested during these mid-cycle tests, but are only tested after refueling during the initial cycle testing of each of the 185 control rods. As such, historical test data shows that a substantial population of individual rods meets the scram time requirements with up to 18 months between tests and provides a basis to conclude that more frequent testing does not provide any conditioning necessary for adequate performance of the control rod scram function. Therefore the future reliability of the Hope Creek scram time performance will not be affected by implementing the proposed change to the mid-cycle periodic testing frequency. An extension from 120 to 200 days of POWER OPERATION, and the associated reduction in the number of rods tested mid-cycle, will not have an adverse affect on the Hope Creek control rod scram function.

The review also determined that only 17 of the 5467 tests yielded a time slow enough to evaluate current TS 3.1.3.4 for the slow control rod. In all of those cases, the average of the 3 fastest control rods in each group of four control rods arranged in a two-by-two array did not exceed the criteria in TS 3.1.3.4. Therefore, Action Statement 3.1.3.4.a did not have to be taken. Using the proposed Table in TS 3.1.3.3-1 for determining "slow" rods, 24 of the tests would have resulted in rods being declared "slow". None of them occupied adjacent locations with other "slow" rods; therefore, the proposed Action Statement 3.1.3.3 would not have been entered. There have been no documented "slow" rods since 2003. Therefore, the justifications for the change presented in TSTF-460 and the model SE are applicable to HCGS.

Hope Creek has been susceptible in recent operating cycles to the phenomenon of channel distortion. Channel distortion has the potential to adversely affect control rod scram performance. Hope Creek currently implements a channel distortion monitoring surveillance program that is in accordance with vendor recommendations and industry standards. The purpose of the program is to reduce the susceptibility of Hope Creek to channel distortion through the core design process, develop analytical models to predict the onset of channel distortion, and establish a testing procedure and acceptance criteria to ensure control rod operability is maintained. This testing typically involves scram time testing and the established acceptance criteria for operability are sufficiently conservative to the TS acceptance criteria.

In addition, the Bases for the proposed change were revised to identify that control rod acceptance criteria for the percentage of allowed "slow" rods would be 7.5% of the at-power surveillance representative sample (revised TS SR 4.1.3.3.b) as opposed to the 20% allowance identified in STS TS 3.1.4 Bases. The more restrictive 7.5% acceptance criterion for testing the representative sample is conservative and consistent with TSTF-460, Rev. 0.

11 of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 5.6 TS 3/4.1.3.5 - Control Rod Scram Accumulators TS 3/4.1.3.5 Action A.1.b and Action A.2.b are being revised to address the option for declaring control rods associated with inoperable accumulators, either "slow" or "inoperable." With the control rod scram accumulator inoperable and the reactor steam dome pressure > 900 psig, the control rod may be declared "slow," since the control rod will still scram at the reactor operating pressure but may not satisfy the required scram times in proposed Table 3.1.3.3-1. The proposed actions are modified by a Note indicating that declaring the control rod "slow" only applies if the associated control scram time was within the limits of Table 3.1.3.3-1 during the last scram time test.

Otherwise, the control rod would already be considered "slow" and the further degradation of scram performance with an inoperable accumulator could result in excessive scram times. In this event, the associated control rod is fully inserted and declared inoperable (Required Action 3.1.3.5.a. 1 .c).

6.0 COMMITMENTS In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear, LLC (PSEG) requests an amendment to Facility Operating Licensing No. NPF-57 for Hope Creek Generating Station (HCGS). The proposed amendment relocates the Technical Specification surveillance requirements for the Reactor Recirculation System MG Set Scoop Tube Stop setpoints to the Technical Requirements Manual (TRM). This proposed change is consistent with changes previously approved by the NRC for other reactor licensees and with Boiling Water Reactor (BWR) Improved Technical Specifications NUREG-1433, Rev. 3.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION The proposed amendment changes HCGS Technical Specifications applicable to control and surveillance of Control Rod Scram Time Testing (TS 3/4.1.3.2, 3/4.1.3.3, and 3/4.1.3.4). Additional changes were proposed to ensure specifications for Control Rod Operability (TS 3/4.1.3.1) and Control Rod Scram Accumulators (TS 3/4.1.3.5) are consistent with the proposed changes. All of the proposed changes are consistent with Standard Technical Specifications and the consideration of determination published on August 23, 2004 (69 FR 51864) for Consolidated Line Item Improvement (CLIIP) for TS Task Force (TSTF) 460 (Revision 0).

PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

i) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes extend the frequency and revise the evaluation methodology for control rod scram times, and identify a new category of "slow" control rods for 12 of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 assessing control rod operability. The frequency of control rod scram testing is not an initiator of any accident previously evaluated. The frequency of surveillance testing does not affect the ability to mitigate any accident previously evaluated, because the tested component is still required to be operable. The proposed evaluation methodology is consistent with industry approved methods and ensures control rod operability requirements for the number and distribution of operable, slow, and stuck control rods continue to satisfy scram reactivity rate assumptions used in plant safety analysis. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

ii) Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No.

The proposed changes do not involve any physical alteration of the plant (no new or different type of equipment is being installed) and do not involve a change in the design, normal configuration, or basic operation of the plant. The proposed changes do not introduce any new accident initiators. The proposed changes do not involve significant changes in the fundamental methods governing normal plant operation and do not require unusual or uncommon operator actions. The proposed changes provide assurance that the plant~will not be operated in a mode or condition that violates the assumptions or initial conditions in the plant safety analyses and that.

SSCs remain capable of performing their intended safety functions as assumed in the same analyses. Consequently, the response of the plant and the~plant operator to postulated events will not be significantly different. Therefore, the proposed TS change does not create the possibility of a new or different kind of accident from any previously evaluated.

iii) Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is related to confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. The proposed changes address control rod scram test performance and acceptance criteria as well as control rod operability requirements. The scram test acceptance criteria and control rod operability restrictions are based on industry approved methodology and will continue to ensure control rod scram design functions and reactivity insertion assumptions used in plant safety analyses continue to be protected. The proposed changes also extend the frequency of testing control rod scram times while at-power from 120 days to 200 days. The proposed change continues to test the control rod scram time to ensure the assumptions in the plant safety analysis are protected. The demonstrated reliability of the control rod scram function justifies the extension of the surveillance frequency. Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

13 of 14

ATTACHMENT 1 LAR H09-06 LR-N09-235 Based on the above, PSEG concludes the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and accordingly, a finding of "no significant hazards consideration" is justified.

8.0 ENVIRONMENTAL EVALUATION The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c) (9). Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment needs to be prepared in connection with the proposed amendment.

9.0 PRECEDENT This application is being made in accordance with the CLIIP and the NRC staff's model SE published on August 23, 2004 (69 FR 51854). PSEG is proposing variations from the TS changes described in TSTF-460 in order to align with NUREG-1433, Rev 3, "Standard Technical Specifications General Regulations General Electric Plants, BWR/4". These changes are similar to those approved by the NRC for Pilgrim Station on November 5, 2007 (TAC No. MD4242)".

10.0 REFERENCES

1) Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specifications Improvement Regarding Revision to the Control Rod Scram Time Testing Frequency in STS 3.1.4, "Control Rod Scram Times" for General Electric Boiling Water Reactors Using the Consolidated Line Item Improvement Process, published August 23, 2004 (69 FR 51854)

2) Letter from R. F Janecek (BWROG) to R.W. Starostecki (NRC) "BWR Owners Group Revised Reactivity Control System Technical Specifications, "dated September 17, 1987 14 of 14

ATTACHMENT 4 LAR H09-06 LR-N09-235 ATTACHMENT 2 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES:

LICENSE AMENDMENT TO ADOPT TSTF 460. REV 0.

The following Technical Specifications for HCGS (Facility Operating License NPF-57) are affected by this change request:

TS No. Title Page INDEX CONTROL RODS v 3.1.3.1 CONTROL RODS 3/4 1-3 4.1.3.1.1 CONTROL RODS- SURVELLIANCE REQUIREMENTS 3/4 1-4 4.1.3.1.3 CONTROL RODS- SURVELLIANCE REQUIREMENTS 3/4 1-5 3.1.3.2 CONTROL ROD MAXIMUM SCRAM INSERTION TIMES 3/4 1-6 4.1.3.2 CONTROL ROD MAXIMUM SCRAM INSERTION TIMES- 3/4 1-6 SURVEILLANCE REQUIREMENTS 3.1.3.3 CONTROL ROD SCRAM INSERTION TIMES 3/4 1-7 4.1.3.3 CONTROL ROD SCRAM INSERTION TIMES- SURVEILLANCE 3/4 1-7 REQUIREMENTS 3.1.3.4 FOUR CONTROL ROD GROUP SCRAM 'INSERTION TIMES 3/4 1-8 4.1.3.4 FOUR CONTROL ROD GROUP SCRAM INSERTION TIMES- 3/4 1-8 SURVEILLANCE REQUIREMENTS 3.1.3.5 CONTROL ROD SCRAM ACCUMULATORS 3/4 1-9

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.0 APPLICABILITY ................................. 3/4 0-1 3/4.1 REACTIVITY CONTROL SYSTEMS 3/4.1.1 SHUTDOWN MARGIN ........................................ 3/4 1-1 3/4.1.2 REACTIVITY ANOMALIES ................................... 3/4 1-2 3/4.1.3 CONTROL RODS Control Rod Operability ................... 3/4 1-3 Control Rod Maximum Scram Insertion Times. 3/4 1-6 Control Rod A-verage Scram Insertion Times. 3/4 1-7 Feur Contrel Red Creup Seram insortien Tim p- 3/4 1 8 Control Rod Scram Accumulators ............ 3/4 1-9 Control Rod Drive Coupling ................ 3/4 1-11 11 Control Rod Position Indication............ 3/4 1-13 Control Rod Drive Housing:Support ......... 3/4 1-15 3/4.1.4 CONTROL ROD PROGRAM CONTROLS Rod Worth Minimizer .................... 3/4 1-16 Rod Sequence Control System (Deleted).. 3/4 1-17 Rod Block Monitor ...................... 3/4 1-18 3/4.1.5 STANDBY LIQUID CONTROL SYSTEM .......................... 3/4 1-19 Figure 3.1.5-1 Sodium Pentaborate Solution Volume/Concentration Requirements ..... 3/4 1-21 3/4.2 POWER DISTRIBUTION LIMITS 3/4.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE ............. 3/4 2-1 HOPE CREEK V Amendment No. 1-0-5

REACTIVITY CONTROL SYSTEMS 3/4.1.3 CONTROL RODS CONTROL ROD OPERABILITY LIMITING CONDITION FOR OPERATION 3.1.3.1 All control rods shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2.

ACTION:

a. With one control rod inoperable due to being immovable, as a result of excessive friction or mechanical interference, or known to be untrippable:

1. oe eithin heur Immediately:

a) Verify that the inoperable control rod, if withdrawn, 4-i saparated fram all ether inaperable eantral reds by at least twa eantral ealle in all dire.tians. meets the stuck control rod separation criteria.

INSERT 1

2. Within two hours:

b+a) Disarm the associated direatienel central valves** hydraulically by closing tha drive watar and exhaust water iselatien valves control rod drive.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

2-- Rest.ara the inaparabla cent*el roed, f withdrawn, La OPERABLE status within 48 heurs ar be in at least I-lO SHUDOW within--P tha nex~t 12 hmu as.

b. With one or more control rods trippable but inoperable for causes other than addressed in ACTION a, above:

1. if the inaperable centLal rad(s) is withdrawn_, within ene three hours:

a) Verify that the ineparable withdrawn centr*l red(s) is separated fra. all ethar ineperable withdrawn eant.ral r.eds by at least twa central aells in all directiens, a b) Demenstrate the insertien aeapability ef the inaperable withdrawn rant.rel r-ed(s) by inserting retch by drive water pressuare wit-hin the nermal eperating rang-eý Otherewise, insert the inoperable withdrawn control rod(s) and disarm tha aeserimated diractieral central valvmFs** either:!

a) Elactrically, er b) Hydraulically by elasing the drive water- and exhaust watr isalatian valves.

The ineparabla central red may then be withdrawn tL a pasitien ne further withdrawn than its pesitien whan faund tL be ineperable.

- May be rearmed intermittently, under administrative central, ta permit tes i ns F) :;#iate ;.with reatarjns

4#11 tIrrta 4red #R OPEýA.RT.P7 Itte

ý-

HOPE CREEK 3/4 1-3

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION ACTION (Continued)

2. If the inoperablc eontrol rod,:) is insef..td, within ene he-i..four hours disarm the associated diroetional control valves** cither control rod drive:

a) Elootr-ieaily, or-b) Hydrouliocily by oloimng ohe drivo w.ater- nd e... ai:i'

... t r isolation valves.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

INSERT 2 3. The provisions of Specification 3.0.4 are not applicable.

ee. With more than 8 control rods inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

df. With one or more scram discharge volume (SDV) vent or drain lines*** with one valve inoperable, isolate the associated line within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .****

eg. With one or more SDV vent or drain lines*** with both valves inoperable, isolate the associated line within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be:in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .****

SURVEILLANCE REQUIREMENTS 4.1.3.1.1 The scram discharge volume drain and vent valves shall be demonstrated OPERABLE by:

a. At I-east once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months verifying each valve to be open,* and

b. At least once per 31 days cycling each valve through at least one complete cycle of full travel.

4.1.3.1.2 When above the low power setpoint of the RWM, all withdrawn control rods not required to have their directional control valves disarmed

These valves may be closed intermittently for testing under administrative controls.

- May be rearmed intermittently, under administrative control, to permit testing associated with restoring the control rod to OPERABLE status

- - Separate Action entry is allowed for each SDV vent and drain line.

- - - An isolated line may be unisolated under administrative control to allow INSERT draining and venting of the SDV.

3 HOPE CREEK 3/4 1-4

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) electrically or hydraulically shall be demonstrated OPERABLE by moving each control rod at least one notch:

a. At least once per 7 days, and

b. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when any control rod is immovable as a result of excessive friction or mechanical interference.

4.1.3.1.3 All control rods shall be demonstrated OPERABLE by performance of Surveillance Requirements 4.1.3.2, 4.1.3.43, 4.1.3.5, 4.1.3.6 and 4.1.3.7.

4.1.3.1.4 The scram discharge volume shall be demonstrated OPERABLE by demonstrating:

a. The scram discharge volume drain and vent valves OPERABLE at least once per 18 months, by verifying that the drain and vent valves:

1. Close within 30 seconds after receipt of a signal for control rods to scram, and

2. Open when the scram signal is reset.

HOPE CREEK 3/4 i-5

REACTIVITY CONTROL SYSTEMS CONTROL ROD MAXIMUM SCRAM INSERTION TIMES LIMITING CONDITION FOR OPERATION 3.1.3.2 The maximum scram insertion time of each control rod from the fully withdrawn position to notch position 5, based on de-energization of the scram pilot valve solenoids as time zero, shall not exceed 7.0 seconds.

APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2.

ACTION:

a. With the maximum scram insertion time of one or more control rods exceeding 7.0 seconds:

1. Declare the control rod(s) with the slow insertion time inoperable,-and

2. Perferm the Surveillance Requirements of Specifieatien 4.1.. '-

at least once per 60 days when operation is continued with three or more control rode With maximum scram insertion timnes in excess of 7.0 seconde.

Otherwise, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.1.3.2 Th eo maximum scram insertion time of the control redo shall be demon scratce cureugn measuremene w*in reaceor oceoan: pressure greater tnan or aaua! to 950 esic and. durino sinýle central red saran time tests. the central ran arive u

* e -*- n ,-rem t--,---

P APPn4l4FA . 4.qTrr

a. For all contro. rods prior to THER... POWER exceeding 40% of RATED THEM.. L POWER following CODE ALTERATIONS or after a reactor Shutdewn that ic greater than 120 days.

b. For specifically affected individual control reds following maintenance on or moedification to the control rod or control rod drive system which could affect thesr-am- insertion time of those specific control rods, and

e. Per at least= !0% of the control rods, on a rotatingl basis, atý least once per 120 200 days of POWER OPERATION.

Verify each control rod scram time from fully withdrawn to notch position 05 is

7.0 seconds in accordance with Surveillance Requirement 4.1.3.3.

HOPE CREEK 3/4 1_-6

REACTIVITY CONTROL SYSTEMS CONTROL ROD AVERAGE SCRAM INSERTION TIMES LIMITING CONDITION FOR OPERATION 3.1.3.3 The Eavcrage scram inscrtien time of all OPERABLE contro-l rods tn*m 9h*"

fully wit.hd.r-awn p*titien, based on de- ncrgization of the scram pilot valve solenoids as time zero, shall not ncocid any of the followine:

Position inserted From Avcragc Scram Insertion Fully Withdrawn Scram Times (a)(b)

(Seconds)

INSERT When Reactor Steam Dome Pressure 4 Notch Position 800 psig 45 0.-4-52 39 0.86 25 1.9-3 05 3.4-4 (a) Maximum scram time from fully withdrawn position, based on de-energization of scram pilot valve solenoids at time zero.

(b) Scram times as a function of reactor steam dome pressure, when < 800 psig are within established limits.

APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2.

ACTION:

With the average scram inscrtion time more than 13 OPERABLE control rods exceeding any of the above limits or more than 2 OPERABLE control rods that are "slow" occupy adjacent locations, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS 4-.1.3.3 All control rods shall ho domonstrated OPERABLE by scram timc testing from the fually withdrawn pecitioen as required by Eur-voillanee Rcquiromont 4.1.3.2. During single control rod scram time surveillances with the control rod drive pumps isolated from the accumulators:

a. Verify each control rod scram time is within the limits of Table 3.1.3.3-1 with reactor steam dome pressure Ž 800 psig prior to THERMAL POWER exceeding 40% RATED THERMAL POWER after each reactor shutdown 120 days.

b. Verify for a representative sample, each tested control rod scram time is within the limits of Table 3.1.3.3-1 with reactor steam dome pressure Ž 800 psig at least once per 200 days of POWER OPERATION.

c. Verify each affected control rod scram time is within the limits of Table 3.1.3.3-1 with any reactor steam dome pressure prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect scram time.

d. Verify each affected control rod scram time is within the limits of Table 3.1.3.3-1 with reactor steam dome pressure Ž 800 psig prior to THERMAL POWER exceeding 40% RATED THERMAL POWER after fuel movement within the affected core cell AND prior to exceeding 40% RTP after work on control rod or CRD System that could affect scram time.

HOPE CREEK 3/4 1-7

REACTIVITY CONTROL SYSTEMS FOUR CONTROL ROD GROUP SCRAM INSERTION TIMES LIMITING CONDITION FOR OPERATION 3.1.3.4 The average scramf inseirtion Limol, fromi the fully withdrawn, position, for the three fastest control roeds in each group of four control reds arranged in a two by two array, based on de enorgization of the scram pilot valve solonoids as time zoro, shall net oxcooed any of the oloig Position inserted From A-verage Scram insertisn Fullly Withdrawn Timeo (Soconds*

n 45 0.45 39 0.92 25 2 .05 05 3.70 APPLICABILITY. OPEPATIONAL CONDITIONS 1 and 2.

ACTION:

a. With the aver-age scram insertion times of control rods oxcooeding the above limits:

1. Doclaro the control rods with the slowor than average scram insertion times inoporablo until an analysis is plrfirmod to determine that rTguirod scram roactivity remains fTr the slow four control rod group, and

2. Porform the Survoillanco Requirements of Specification 4.1.3.2-.e at least onc o per 60 days when eperatien is continuod with an avoýrago secram insortion timoe(s) in exese the average scram insortion timo limit.

Gthorwiso, bo in at least HO9T SHUTDOWN within the next 1:2 hours.

b. The provisions of Spocifieation 3.0.4 are net applicabloe.

SURVEILLANCE REQUIREMENTS 4.1.3.4 All control rods shall be domonstra t ed OPERABLE by se-ram timo-testing from the fully withdrawn position as required by Su rycFpi I I ;;n p p Rogiuiromoint 4.1.3.2.

HOPE CREEK 3/4 1-8

REACTIVITY CONTROL SYSTEMS CONTROL ROD SCRAM ACCUMULATORS LIMITING CONDITION FOR OPERATION 3.1.3.5 Each control rod scram accumulator shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 5*.

ACTION:

NOTE---------------------------------

Separate condition entry is allowed for each control rod

a. In OPERATIONAL CONDITIONS 1 or 2:

1. With one control rod scram accumulator inoperable and reactor pressure Ž 900 psig, within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , a) Restore the inoperable accumulator to OPERABLE status, or b) Declare the associated control rod scram time "slow"***,

or b--c) Insert the associated control rod, declare the associated control rod inoperable and disarm the associated control valves either clctrically or hydraulieally by closing the drive water and exhaust water isolation valves.

Otherwise, be in at least HOT SHUTDOWN with the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

2. With two or more control rod scram accumulators inoperable and reactor pressure Ž 900 psig, a) Within 20 minutes of discovery of this condition concurrent with charging water pressure < 940 psig, restore charging water header pressure to Ž 940 psig otherwise place the mode switch in the shutdown position**,

and b) Within one hour, declare the associated control rod scram time "slow"***, or b4ýc) Within one hour insert the associated control rods, declare the associated control rods inoperable and disarm the associated control valves either eleetri.ally er hydraulically by closing the drive water and exhaust water isolation valves.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At least the accumulator associated with each withdrawn control rod. Not applicable to control rods removed per Specification 3.9.10.1 or 3.9.10.2.

- Not applicable if all inoperable control rod scram accumulators are associated with fully inserted control rods.

- - Only applicable if the associated control rod scram time was within the limits of Table 3.1.3.3-1 during the last scram time Surveillance. Rods that are already considered "slow" should be declared inoperable and fully inserted.

HOPE CREEK 3/4 1-9 Amendment No. 49

INSERT I Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

INSERT 2

c. With two or more inoperable control rods not in compliance with banked position withdrawal sequence (BPWS) and not separated by two or more OPERABLE control rods*****:

1. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , restore compliance with BPWS, or

2. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , restore control rod(s) to OPERABLE status, or

3. Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , verify control rod drop accident limits are met.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

d. One or more BPWS groups with four or more inoperable control rods*****, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , restore control rod(s) to OPERABLE status.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

INSERT 3 Not applicable when THERMAL POWER is greater than 8.6% RATED THERMAL POWER.

INSERT 4 No more than 13 OPERABLE control rods shall be "slow," in accordance with Table 3.1.3.3-1, and no more than 2 OPERABLE control rods that are "slow" shall occupy adjacent locations.

Table 3.1.3.3-1

------------------ NOTES---------------------------------------

1. OPERABLE control rods with scram times not within the limits of this Table are considered "slow."

2. Enter applicable Conditions and Required Actions of LCO 3.1.3.2, "Control Rod Maximum Scram Insertion Times," for control rods with scram times > 7.0 seconds to notch position 05. These control rods are inoperable in accordance with SR 4.1.3.2 and are not considered "slow."

ATTACHMENT 3 LAR H09-02 LR-N09-235 ATTACHMENT 3 (Information Only)

BASES PAGES WITH PROPOSED CHANGES:

LICENSE AMENDMENT TO ADOPT TSTF 460, REV 0.

The following Technical Specification Bases for HCGS (Facility Operating License DPR-70) are affected by this change request:

Bases No. Title Page 3/4.1.3 CONTROL RODS 1-2 1-2a 1-2b 1-5

REACTIVITY CONTROL SYSTEMS BASES 3/4.1.3 CONTROL RODS The specifications of this section ensure that (1) the minimum SHUTDOWN MARGIN is maintained, (2) the control rod insertion times are consistent with those used in the accident analysis, and (3) limit the potential effects of the rod drop accident. The ACTION statements permit variations from the basic requirements but at the same time impose more restrictive criteria for continued operation. A limitation on inoperable rods is set such that the resultant effect on total rod worth and scram shape will be kept to a minimum. The requirements for the various scram time measurements ensure that any indication of systematic problems with rod drives will be investigated on a timely basis.

The operability of an individual control rod is based on a combination of factors, primarily, the scram insertion times, the control rod coupling integrity, and the ability to determine the control rod position. Accumulator operability is addressed by LCO 3.1.3.5. The associated scram accumulator status for a control rod only affects the scram insertion times; therefore, an inoperable accumulator does not immediately require declaring a control rod inoperable. Although not all control rods are required to be operable to satisfy the intended reactivity control requirements, control over the number of inoperable control rods is required.

Insert 0 Control rod insertion capability is demonstrated by surveillance 4.1.3.1.2 inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves. The control rod may then be returned to its original position. This ensures the control rod is not stuck and is free to insert on a scram signal. At any time, a control rod is immovable for reasons not associated with the control rod drive mechanism, a determination of that control rod's trippability (Operability) must be made and appropriate actions taken. As an example, if the control rod can be scrammed, but can not be moved due to a RMCS failure, the rod(s) may continue to be considered OPERABLE provided all other related surveillances are current.

Damage within the control rod drive mechanism could be a generic problem, therefore with a withdrawn control rod immovable because of excessive friction or mechanical interference, operation of the reactor is limited to a time period which is reasonable to determine the cause of the inoperability and at the same time prevent operation with a large number of inoperable control rods.

Control rods that are inoperable for other reasons are permitted to be taken out of service provided that those in the nonfully-inserted position are consistent with the SHUTDOWN MARGIN requirements.

The number of control rods permitted to be inoperable could be more than the eight allowed by the specification, but the occurrence of eight inoperable rods could be indicative of a generic problem and the reactor must be shutdown for investigation and resolution of the problem.

HOPE CREEK B 3/4 1-2 Amendment No. -94

REACTIVITY CONTROL SYSTEMS BASES CONTROL RODS (Continued)

The control r-od system is designed to bring the reactor suberitieal at a rate fast eneugh to prevent the MCPR *from becoming less than the fuel cladding Safety Limit during the lim..iting power transient analyzed in Seetion . 5.. of the FSAR. Thianlis shows that- the negative rceactivity r~ates r~esulti4ng fromf the-scram with . response f all the drives as given in the specifications, provide the required protection and remains greater than

,PMC the fuel cladding Safety imi4t. The.... rre..e of scram times longer then the specified should be viewed as an indication of a systematic problem with the red drives and therefore the surveillanee interval is reduced in order to prevent serious operation of the .eactor fer long per-ds of time with a potentially problemf.

Insert 2 The scram discharge volume is required to be OPERABLE so that it will be available when needed to accept discharge water from the control rods during a reactor scram and will isolate the reactor coolant system from the containment when required.

Control rods with inoperable accumulators are declared inoperable and Specification 3.1.3.1 then applies. This prevents a pattern of inoperable accumulators that would result in less reactivity insertion on a scram than has been analyzed. The OPERABILITY of the control rod scram accumulators is required to ensure that adequate scram insertion capability exists when needed over the entire range of reactor pressures. The OPERABILITY of the scram accumulators is based on maintaining adequate accumulator pressure.

In OPCON 1 and 2, the scram function is required for mitigation of DBAs and transients, and therefore the scram accumulators must be OPERABLE to support the scram function. In OPCON 3 and 4, control rods are only allowed to be withdrawn under limits imposed by the reactor mode switch being in shutdown and by the control rod block being applied. This provides adequate requirements for control rod scram accumulator OPERABILITY during these conditions. In OPCON 5, withdrawn control rods are required to have OPERABLE accumulators.

The actions of Specification 3.1.3.5 are modified by a note indicating that a separate Condition entry is allowed for each control rod scram accumulator.

This is acceptable since the required Actions for each Condition provide appropriate compensatory actions for each affected accumulator. Complying with the Required Actions may allow for continued operation and subsequent affected accumulators governed by subsequent Condition entry and application of associated Required Actions.

Insert 3 With two or more control rod scram accumulators inoperable and reactor pressure > 900 psig, adequate pressure must be supplied to the charging water header. With inadequate charging water pressure, the accumulators could HOPE CREEK 8 3/4 1-2a Amendment No. -94

REACTIVITY CONTROL SYSTEMS BASES CONTROL RODS (Continued) become inoperable, resulting in a potential degradation of the scram performance. Therefore, within 20 minutes from discovery of charging water header pressure < 940 psig concurrent with conditions in Action 3.1.3.5.a.2, adequate charging water header pressure must be restored. The allowed Completion Time of 20 minutes is reasonable, to place a CRD pump into service to restore the charging header pressure, if required. This Completion Time is based on the ability of the reactor pressure alone to fully insert all control Insert _S

ý4 With one or more control rod scram accumulators inoperable and the reactor pressure < 900 psig, the pressure supplied to the charging water header must be adequate to ensure that accumulators remain charged. With the reactor pressure

< 900 psig, the function of the accumulators in providing the scram force becomes much more important since the scram function could become degraded during a depressurization event or at low reactor pressures. Therefore, immediately upon discovery of charging water header pressure < 940 psig, concurrent wit h conditions in Action 3.1.3.5.a.3, all control rods associated with inoperable accumulators must be verified to be fully inserted. Withdrawn control rods with inoperable accumulators may fail to scram under these low pressure conditions. The associated control rods must also be inserted, declared inoperable, and disarmed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The allowed Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable considering the low probability of DBA or transient occurring during the time that the accumulator is inoperable.

The reactor mode switch must be immediately placed in the shutdown position if either Required Action and associated Completion Time associated with loss of the CRD charging pump (Required Actions 3.1.3.5.a.2.a or 3.1.3.5.a.3.a) cannot be met. This ensures that all insertable control rods are inserted and that the reactor is in condition that does not require the active function (i.e., scram) of the control rods. This Required Action is modified by a note stating that the action is not applicable if all control rods associated with the inoperable scram accumulators are fully inserted, since the function of the control rods has been performed.

Surveillance Requirement 4.1.3.5 requires that the accumulator pressure be checked every 7 days to ensure adequate accumulator pressure exists to provide sufficient scram force. The primary indicator of accumulator OPERABILITY is the accumulator pressure. A minimum accumulator pressure is specified, below which the capability of the accumulator to perform its intended function becomes degraded and the accumulator is considered inoperable. Declaring the accumulator inoperable when the minimum pressure is not maintained ensures that significant degradation in scram times does not occur. The 7 day frequency has been shown to be acceptable through operating experience and takes into account indications available in the control room.

Control rod coupling integrity is required to ensure compliance with the analysis of the rod drop accident in the FSAR. The overtravel position HOPE CREEK B 3/4 1-2b Amendment No. 4-8--

REACTIVITY CONTROL SYSTEMS BASES rate, solution concentration or boron equivalent to meet the ATWS Rule must not invalidate the original system design basis. Paragraph (c) (4) of 10 CFR 50.62 states that:

"Each boiling water reactor must have a Standby Liquid Control System (SLCS) with a minimum flow capacity and boron control equivalent in control capacity to 86 gallons per minute of 13 weight percent sodium pentaborate solution (natural boron enrichment)."

The described minimum system parameters (82.4 gpm, 13.6 percent concentration and natural boron equivalent) will ensure an equivalent injection capability that exceeds the ATWS Rule requirement. The stated minimum allowable pumping rate of 82.4 gallons per minute is met through the simultaneous operation of both pumps.

The standby liquid control system will also provide the capability to raise and maintain the long-term post-accident coolant inventory pH levels to 7 or above. This will prevent significant fractions of the dissolved iodine from being converted to elemental iodine and then re-evolving to the containment atmosphere.

1. NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel,"

(latest approved version).

Insert5 HOPE CREEK B 3/4 1-5 Amendment No. --S-

Insert 1 Acontrol rod is considered stuck if it will not insert by either CRD drive water or scram pressure.

With a fully inserted control rod stuck, no actions are required as long as the control rod remains fully inserted. With one withdrawn control rod stuck, the local scram reactivity rate assumptions may not be met if the stuck control rod separation criteria are not met. Therefore, verification that the separation criteria are met must be performed immediately. Consistent with STS, HCGS will consider "immediately" to mean "the Required Action should be pursued without delay and in a controlled manner. The separation criteria are not met if: a) the stuck control rod occupies a location adjacent to two "slow" control rods, b) the stuck control rod occupies a location adjacent to one "slow" control rod, and the one "slow" control rod is also adjacent to another "slow" control rod, or c) if the stuck control rod occupies a location adjacent to one "slow" control rod when there is another pair of "slow" control rods adjacent to one another. The description of "slow" control rods is provided in LCO 3.1.3.3, "Control Rod Scram Times." In addition, the associated control rod drive must be disarmed in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The allowed Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is acceptable, considering the reactor can still be shut down, assuming no additional control rods fail to insert, and provides a reasonable time to perform the Required Action in an orderly manner. Isolating the control rod from scram prevents damage to the CRDM. The control rod can be isolated from normal insert and withdraw pressure, yet still maintain cooling water to the CRD.

With two or more withdrawn control rods stuck, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The occurrence of more than one control rod stuck at a withdrawn position increases the probability that the reactor cannot be shut down if required. Insertion of all insertable control rods eliminates the possibility of an additional failure of a control rod to insert. The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

With one or more control rods inoperable for reasons other than being stuck in the withdrawn position, operation may continue, provided the control rods are fully inserted within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and disarmed (electrically or hydraulically) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Inserting a control rod ensures the shutdown and scram capabilities are not adversely affected. The control rod is disarmed to prevent inadvertent withdrawal during subsequent operations. The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves. The control rods can be electrically disarmed by disconnecting all four directional control valve solenoids.

The allowed Completion Times are reasonable, considering the small number of allowed inoperable control rods, and provide time to insert and disarm the control rods in an orderly manner and without challenging plant systems.

Out of sequence control rods may increase the potential reactivity worth of a dropped control rod during a CRDA. At < 8.6% RTP, the generic banked position withdrawal sequence (BPWS) analysis requires inserted control rods not in compliance with BPWS to be separated by at least two OPERABLE control rods in all directions, including the diagonal. Therefore, iftwo or more inoperable control rods are not in compliance with BPWS and not separated by at least two OPERABLE control rods, action must be taken to restore compliance with BPWS or restore the control rods to OPERABLE status. LCO 3.1.3.1 .c is modified by a Note indicating that the Condition is not applicable when > 8.6% RTP, since the BPWS is not required to be followed under these conditions, as described in the Bases for LCO 3.1.4. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is acceptable, considering the low probability of a CRDA occurring. In lieu of

restoring compliance with BPWS or restoring the control rods to OPERABLE status, an evaluation of the postulated CRDA may be performed to verify that the maximum incremental rod worth of an assumed dropped control rod would not result in exceeding the CRDA design limit of 280 cal/gm fuel enthalpy and would not result in unacceptable dose consequences due to the number of fuel rods exceeding 170 cal/gm fuel enthalpy as described in the UFSAR. The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is acceptable, considering the low probability of a CRDA occurring.

In addition to the separation requirements for inoperable control rods, an assumption in the CRDA analysis is that no more than three inoperable control rods are allowed in any one BPWS group. Therefore, with one or more BPWS groups having four or more inoperable control rods, the control rods must be restored to OPERABLE status. LCO 3.1.3.1 .d is modified by a Note indicating that the Condition is not applicable when THERMAL POWER is > 8.6% RTP since the BPWS is not required to be followed under these conditions, as described in the Bases for LCO 3.1.4. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is acceptable, considering the low probability of a CRDA occurring.

Insert 2 Verifying that the scram time for each control rod to notch position 05 is < 7 seconds (SR 4.1.3.2) provides reasonable assurance that the control rod will insert when required during a DBA or transient, thereby completing its shutdown function. This SR is performed in conjunction with the control rod scram time testing of SR 4.1.3.3.

The scram times specified in Table 3.1.3.3-1 (in the accompanying LCO) are required to ensure that the scram reactivity assumed in the Design Basis Accident (DBA) and transient analysis is met (Ref. 2). To account for single failures and "slow" scramming control rods, the scram times specified in Table 3.1.3.3-1 are faster than those assumed in the design basis analysis. The scram times have a margin that allows up to approximately 7% of the control rods (e.g., 185 x 7% = 13) to have scram times exceeding the specified limits (i.e., "slow" control rods) assuming a single stuck control rod (as allowed by LCO 3.1.3.1, "Control Rod OPERABILITY") and an additional control rod failing to scram per the single failure criterion. The scram times are specified as a function of reactor steam dome pressure to account for the pressure dependence of the scram times. The scram times are specified relative to measurements based on reed switch positions, which provide the control rod position indication. The reed switch closes

("pickup") when the index tube passes a specific location and then opens ("dropout") as the index tube travels upward. Verification of the specified scram times in Table 3.1.3.3-1 is accomplished through measurement of the "dropout" times. To ensure that local scram reactivity rates are maintained within acceptable limits, no more than two of the allowed "slow" control rods may occupy adjacent locations.

Table 3.1.3.3-1 is modified by two Notes which state that control rods with scram times not within the limits of the Table are considered "slow" and that control rods with scram times > 7 seconds are considered inoperable as required by SR 4.1.3.2.

This LCO (3.1.3.3) applies only to OPERABLE control rods since inoperable control rods will be inserted and disarmed (LCO 3.1.3.1). Slow scramming control rods may be conservatively declared inoperable and not accounted for as "slow" control rods.

Maximum scram insertion times occur at a reactor steam dome pressure of approximately 800 psig because of the competing effects of reactor steam dome pressure and stored accumulator energy. Therefore, demonstration of adequate scram times at reactor steam dome pressure >

800 psig ensures that the measured scram times will be within the specified limits at higher pressures. Limits are specified as a function of reactor pressure to account for the sensitivity of the scram insertion times with pressure and to allow a range of pressures over which scram time testing can be performed. To ensure that scram time testing is performed within a reasonable time following a shutdown > 120 days or longer, control rods are required to be tested before exceeding 40% RTP following the shutdown. This Frequency is acceptable considering the additional surveillances performed for control rod OPERABILITY, the frequent verification of adequate accumulator pressure, and the required testing of control rods affected by fuel movement within the associated core cell and by work on control rods or the CRD System.

Additional testing of a sample of control rods is required to verify the continued performance of the scram function during the cycle. A representative sample contains at least 10% of the control rods. The sample remains representative if no more than 7.5% of the control rods in the sample tested are determined to be "slow." With more than 7.5% of the sample declared to be "slow" per the criteria in Table 3.1.3.3-1, additional control rods are tested until this 7.5%

criterion (e.g., 7.5% 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. Data from inadvertent scrams should be used whenever possible to avoid unnecessary testing at power, even if the control rods with data may have been previously tested in a sample. The 200 day Frequency is based on operating experience that has shown control rod scram times do not significantly change over an operating cycle. This Frequency is also reasonable based on the additional Surveillances done on the CRDs at more frequent intervals in accordance with LCO 3.1.3.1 and LCO 3.1.3.5, "Control Rod Scram Accumulators."

When work that could affect the scram insertion time is performed on a control rod or the CRD System, testing must be done to demonstrate that each affected control rod retains adequate scram performance over the range of applicable reactor pressures from zero to the maximum permissible pressure. The scram testing must be performed once before declaring the control rod OPERABLE. The required scram time testing must demonstrate the affected control rod is still within acceptable limits. The limits for reactor pressures < 800 psig are established based on a high probability of meeting the acceptance criteria at reactor pressures > 800 psig. Limits for > 800 psig are found in Table 3.1.3.3-1. If testing demonstrates the affected control rod does not meet these limits, but is within the 7-second limit of Table 3.1.3.3-1, Note 2, the control rod can be declared OPERABLE and "slow."

Specific examples of work that could affect the scram times are (but are not limited to) the following: removal of any CRD for maintenance or modification; replacement of a control rod; and maintenance or modification of a scram solenoid pilot valve, scram valve, accumulator, isolation valve or check valve in the piping required for scram.

The Frequency of once prior to declaring the affected control rod OPERABLE is acceptable because of the capability to test the control rod over a range of operating conditions and the more frequent surveillances on other aspects of control rod OPERABILITY.

When work that could affect the scram insertion time is performed on a control rod or CRD System, or when fuel movement within the reactor pressure vessel occurs, testing must be done to demonstrate each affected control rod is still within the limits of Table 3.1.3.3-1 with the reactor steam dome pressure >_800 psig. Where work has been performed at high reactor pressure, the requirements of SR 4.1.3.3.c and SR 4.1.3.3.d can be satisfied with one test. For a control rod affected by work performed while shut down, however, a zero pressure and high pressure test may be required. This testing ensures that, prior to withdrawing the control rod for continued operation, the control rod scram performance is acceptable for operating reactor pressure conditions. Alternatively, a control rod scram test during hydrostatic pressure testing could also satisfy both criteria. When fuel movement within the reactor pressure vessel occurs, only those control rods associated with the core cells affected by the fuel movement are required to be scram time tested. During a routine refueling outage, it is expected that all control rods will be affected.

The Frequency of once prior to exceeding 40% RTP is acceptable because of the capability to test the control rod over a range of operating conditions and the more frequent surveillances on other aspects of control rod OPERABILITY.

Insert 3 With one control rod scram accumulator inoperable and the reactor steam dome pressure > 900 psig, the control rod may be declared "slow," since the control rod will still scram at the reactor operating pressure but may not satisfy the required scram times in Table 3.1.3.3-1. Required Action 3.1.3.5.b is modified by a Note indicating that declaring the control rod "slow" only applies if the associated control scram time was within the limits of Table 3.1.3.3-1 during the last scram time test. Otherwise, the control rod would already be considered "slow" and the further degradation of scram performance with an inoperable accumulator could result in excessive scram times. In this event, the associated control rod is fully inserted and declared inoperable (Required Action 3.1.3.5.a.1.c). The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on the large number of control rods available to provide the scram function and the ability of the affected control rod to scram only with reactor pressure at high reactor pressures.

Insert 4 The control rod may be declared "slow," since the control rod will still scram using only reactor pressure, but may not satisfy the times in Table 3.1.3.3-1. Required Action 3.1.3.5.a.2.b is modified by a Note indicating that declaring the control rod "slow" only applies if the associated control scram time is within the limits of Table 3.1.3.3-1 during the last scram time test.

Otherwise, the control rod would already be considered "slow" and the further degradation of scram performance with an inoperable accumulator could result in excessive scram times. In this event, the associated control rod is fully inserted and declared inoperable (Required Action 3.1.3.5.a.2.c). The allowed Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the ability of only the reactor pressure to scram the control rods and the low probability of a DBA or transient occurring while the affected accumulators are inoperable.

Insert 5

6. Letter from R.F. Janecek (BWROG) to R.W. Starostecki (NRC), "BWR Owners Group Revised Reactivity Control System Technical Specifications," BWROG-8754, September 17, 1987.

ATTACHMENT 4 LAR H09-06 LR-NOO-235 ATTACHMENT 4 LIST OF REGULATORY COMMITMENTS FOR LICENSE AMENDMENT TO ADOPT TSTF 460, REV 0.

The following table identifies those actions committed to in this document by PSEG for Hope Creek Generating Station (HCGS). Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Please direct questions regarding these commitments to Jeffrie Keenan, Licensing Manager, at (856) 339-5429.

REGULATORY COMMITTMENT DUE DATE/EVENT HCGS will incorporate the revised This commitment will be implemented acceptance criterion for the percentage of within 60 days from the date of the allowed "slow" rods of 7.5 percent into the approval of the proposed amendment.

TS Bases for HCGS in accordance with the Bases Control Program described in TS [5.5.14].

HCGS will incorporate the 90% (notch 05), This commitment will be implemented zero pressure insertion limit of 2 seconds within 60 days from the date of the into the Technical Requirements Manual approval of the proposed amendment.

(TRM) as the acceptance criterion for proposed SR 4.1.3.3.c.

Page 1 of 1

v t e Letter Sequence Request
TAC:ME2815, Control Rod SCRAM Time Testing Frequency (Approved, Closed)
Initiation Request Acceptance Supplement, Supplement Administration Questions Answers Results Approval Other:
MONTHYEAR2010-07-23 [Table View]

ML093430242

Text

Subject:

1.0 INTRODUCTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

5.0 TECHNICAL ANALYSIS

8.0 ENVIRONMENTAL CONSIDERATION

10.0 REFERENCES

1.0 INTRODUCTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

5.0 TECHNICAL ANALYSIS

10.0 REFERENCES

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