ML042110342

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License Amendment Request Proposed Changes to Control Rod Requirements
ML042110342
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 07/22/2004
From: Gallagher M
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML042110342 (20)


Text

Exeltns.

Exelon Nuclear www.exeloncorp.com Nuclear 200 Exelon Way Kennett Square, PA 19348 10 CFR 50.90 July 22, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

SUBJECT:

License Amendment Request Proposed Changes to Control Rod Requirements Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit,"

Exelon Generation Company, LLC (Exelon), hereby requests the following amendment to the Technical Specifications (TS), Appendix A of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.

The application proposes changes to the control rod operability and surveillance requirements specified in TS 3/4.1.3, "Control Rods." Specifically, the changes would (1) exclude a fully inserted immovable control rod from the shutdown action statement, (2) eliminate consideration of control rod drive water pressure in the action statement, and (3) limit the 24-hour exercise test of other control rods to a one time occasion following detection of an immovable control rod.

The requested changes do not inhibit the design function of the control rod shutdown system.

Additionally, the changes are consistent with the improved standard TS presented in the NRC document titled: "Standard Technical Specifications - General Electric Plants, BWR/4," NUREG-1433, Rev. 2.

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10CFR 50.92.

Exelon requests approval of the proposed amendment within one year from the submittal date.

Upon NRC approval, the amendment shall be implemented within 60 days of issuance.

These proposed changes have been reviewed by the Plant Operations Review Committee, and approved by the Nuclear Safety Review Board.

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LGS Units 1&2: Proposed Changes To Control Rod Requirements July 22, 2004 Page 2 We are notifying the State of Pennsylvania of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Doug Walker at (610) 765-5726.

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

Respectfully, Executed on, 4z//,

  • Michael P. Gallagher Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes
2. Technical Specifications Marked-Up Pages
3. Technical Specifications Typed Pages cc: H. J. Miller, Administrator, Region I, USNRC (w/enc)

A. L. Burritt, USNRC Senior Resident Inspector, LGS 4'

T. Tate, Project Manager, NRR USNRC R. R. Janati, Pennsylvania Department of Environmental Resources

ATTACHMENT 1 License Amendment Request Limerick Generating Station Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to Control Rod Requirements EVALUATION OF PROPOSED CHANGES TO CONTROL ROD REOUIREMENTS CONTENTS

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

S

3.0 TECHNICAL ANALYSIS

4.0 REGULATORY ANALYSIS

4.1 No Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

1

LGS U1&2: Evaluation of Proposed Attachment 1 Changes to Control Rod Requirements Page 2 of 8 EVALUATION OF PROPOSED CHANGES TO CONTROL ROD REQUIREMENTS

1.0 DESCRIPTION

The proposed changes would revise the Facility Operating Licenses Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. The changes apply to (1) the Technical Specification (TS) action statement (3.1.3.1.a) for one immovable control rod, (2) the TS action statement (3.1.3.1.b.1.b) for demonstrating the insertion capability of inoperable control rods, and (3) the operability test of all withdrawn control rods every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when any control rod is immovable (TS 4.1.3.1.2.b). Fully inserted, disarmed, control rods are in a safe position of maximum contribution to shutdown reactivity, and therefore, do not compromise reactor shutdown capability. Under the current TS, an immovable control rod in the fully inserted, disarmed configuration, requires a 48-hour plant shutdown, and triggers exercise testing of all withdrawn control rods every 24-hours. The proposed changes would limit the operability requirements for immovable control rods to partially or fully withdrawn rods, and the 24-hour accelerated exercise test to a one-time requirement. Further, a proposed change would eliminate the requirement to maintain drive water pressure within the normal operating range during control rod insertion capability testing upon discovery of an inoperable, but trippable, control rod. The proposed changes will not impede the ability of the surveillance requirements to detect control rod degradation, nor inhibit the control rod drive system from performing its designed safety function. Additionally, the changes are consistent with the improved standard TS presented in the NRC document titled: "Standard Technical Specifications - General Electric Plants, BWR/4," NUREG-1433, Rev. 2.

2.0 PROPOSED CHANGE

Changes requested by this amendment application are:

Change1 Revise TS 3.1.3.1.a action statement as follows:

  • Insert "withdrawn" before "control rod" in TS action statement 3.1.3.1.a, and
  • Delete "if withdrawn" from TS action statement 3.1.3.1.a.1.a, and
  • Insert "withdrawn" before "control rod" in TS action statement 3.1.3.1.a.2.

The revised TS 3.1.3.1.a action statement would read as follows (additions shown in bold type):

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

1. Within 1 hour:

a) Verify that the inoperable withdrawn control rod is separated from all other inoperable withdrawn control rods by at least two control cells in all directions.

LGS U1&2: Evaluation of Proposed Attachment 1 Changes to Control Rod Requirements Page 3 of 8 b) Disarm the associated directional control valves** either:

1) Electrically, or
2) 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Restore the inoperable withdrawn control rod to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Change 2 Delete "by drive water pressure within the normal operating range" from TS action statement 3.1.3.1.b.1.b. The revised action statement would read as follows:

"b) Demonstrate the insertion capability of the inoperable withdrawn control rod(s) by inserting the control rod(s) at least one notch*."

Change 3 Revise TS 4.1.3.1 .2.b surveillance requirement by replacing "At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when any" with "Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery that a" (addition shown in bold type):

"b. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery that a control rod is immovable as a result of excessive friction or mechanical interference."

Implementation of the amendment will be performed within 60 days of NRC issuance of the amendment.

3.0 TECHNICAL ANALYSIS

The proposed license amendment would (1) limit the applicability of the shutdown action statement for immovable control rod(s) to only those in the withdrawn position, (2) eliminate the requirement that the control rod drive pressure be within the normal operating range during the demonstration of the insertion capability of inoperable, but trippable, control rod(s), and (3) change the requirement to perform an operability test of other control rods every 24-hours upon discovery of an immovable control rod, to a non-repetitive test performed once within 24-hours of discovery.

Change 1 (TS 31 31 a)-

This action statement currently requires a reactor shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> upon discovery of an immovable (stuck) control rod, irrespective of its position. Therefore an immovable control rod in the fully inserted position, as well as a rod in the withdrawn position, is subject to this shutdown action statement. The proposed change would exclude fully inserted control rods from consideration in the immovable control rod action statement. The change will not degrade or inhibit the control rod drive system from performing its design function. The control rod system provides reactor shutdown capability from all operating conditions, transients, and design basis events, with sufficient shutdown reactivity margin. A control rod that has been fully

LGS U1&2: Evaluation of Proposed Attachment 1 Changes to Control Rod Requirements Page 4 of 8 inserted, and disarmed, has satisfied the safety function of that control rod since it is in a position of maximum contribution to shutdown reactivity.

A control rod in the fully inserted, disarmed configuration equates to having any nuclear safety system component in the tripped, or fail-safe, condition. For example, if an inoperable reactor protection system (RPS) instrument channel is placed in the tripped position, continued safe operation of the reactor is assured. The number of inoperable tripped RPS channels is only limited by the number of tripped channels required to affect an automatic shutdown inherent in the design of the system. Similarly, the number of inoperable control rods in the fully inserted (tripped) position does not in itself reduce the reactor safe shutdown capability, and is only limited by the control rod pattern restrictions needed to comply with the power distribution limits in the LGS Technical Specifications, Section 2. The proposed change has the potential of avoiding unnecessary thermal cycles to the plant.

The proposed change will not change the requirement of TS 3.1.3.1.c that inoperable control rods, whether fully inserted or withdrawn, not exceed 8 control rods during power operations.

Accordingly, immovable control rods in the fully inserted position would be counted in the operability requirement precluding power operation with more than 8 inoperable control rods.

The requirement in the current TS 3.1.3.1.b.2 that inoperable control rods in the fully inserted position be disarmed will not be altered by this amendment request. Disarming the control rod either electrically or hydraulically precludes inadvertent withdrawal during subsequent operations. Further, under the proposed change, current action statement 3.1.3.1.a will continue to apply to partially or fully withdrawn immovable control rods. Accordingly, the operability requirements needed to assure the reliability of the control rod drive system are not impacted by the proposed change.

Change 2 (TS 3-1.3.1.h.i.h):

This action statement requires a demonstration of the insertion capability of an inoperable withdrawn control rod that is not immovable (non-stuck). The demonstration involves inserting the control rod at least one notch using drive water pressure within the normal operating range.

The proposed change would eliminate the requirement for water pressure to be within the normal operating range.

The Control Rod Drive (CRD) hydraulic system supplies and controls the pressure and flow to and from the drives. The CRD pressure is maintained by the drive pressure control valve, which is manually adjusted from the control room. Normally the CRD pressure is maintained between 255 to 265 psig above reactor pressure. Control rod positioning occurs when a manual control signal opens the drive and exhaust directional control solenoid valves, creating a differential pressure across the CRD piston. Occasionally, to effect positioning for a specific control rod, the CRD pressure must be adjusted upwards, sometimes to as much as 350 psig above reactor pressure. These higher than normal drive pressures are attributed to normal, age related internal seal degradation, mechanical friction, crud or gas intrusion into the drive mechanism, or a directional control valve malfunction. Technical papers BWROG-CRD-03-B (reference 2) and BWROG-CRD-00-A (reference 3), and NUREG/CR-5699 (reference 4) cite the aforementioned conditions as potential reasons for not being able to reposition a control rod drive mechanism using the normal drive water pressure setting. Moreover, TS surveillance requirement 4.1.3.1.2, which demonstrates operability by ensuring that each control rod drive can be successfully inserted at least one notch position, does not include drive water pressure restrictions similar those specified in TS 3.1.3.1.b.1.b.

LGS U1&2: Evaluation of Proposed Attachment 1 Changes to Control Rod Requirements Page 5 of 8 The CRD pressure setting is unrelated to the reactor shutdown safety function to effect the rapid insertion of control rods (scram). Reactor pressure, assisted by a pre-charged accumulator, provides the driving force for scram, independent of the CRD pressure. The scram insertion times of all control rods are measured after each core alteration outage, or outages more than 120 days, and on a rotating basis during power operation. Routine exercise testing of withdrawn control rods assures the absence of stuck control rods. These surveillance tests assure reactor shutdown capability. The requirement to demonstrate the insertion capability of an inoperable withdrawn control rod by inserting the rod at least one notch will remain; however, the restriction on drive water pressure would be eliminated. In summary, a higher required CRD pressure is not an indicator of a condition that inhibits the safety function of the control rod. The proposed change would eliminate the need to unnecessarily insert a control rod into the core if it could not be inserted using the normal drive water pressure setting.

Finally, the proposed change will provide congruity between TS surveillance requirement 4.1.3.1.2 and TS 3.1.3.1.b.1.b.

Change 3 (TS 4 1 3 1.2):

This surveillance requires an increased frequency (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) exercise test of all withdrawn control rods if any control rod, irrespective of its position, is immovable (stuck). Proposed change 1, discussed above, would permit continued power operation with one or more immovable control rods provided it is in the fully inserted position, and other requirements in the Technical Specifications regarding power distribution limits are satisfied. For the situation with an immovable control rod in the fully inserted position, current surveillance requirement 4.1.3.1.2 requires an insertion capability test of all withdrawn control rods within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery, and every 24-hours thereafter.

Upon discovery of an immovable control rod, the 24-hour exercise test provides assurance that there is not a generic problem that may result in other immovable control rods. If the first 24-hour test confirms the operability of the other control rods, the issue of concern regarding a potential generic problem is resolved. Continued 24-hour exercise testing provides no additional information regarding a generic control rod problem, and has the potential to reduce the operable lifespan of hydraulic control unit components without any compensatory safety benefit. The proposed change would require only a one time test within 24-hours, and in the absence of additional control rod problems, the testing will revert back to the routine exercise schedule. The routine exercise testing assures the continued operability of the control rod drive system.

4.0 REGULATORY ANALYSIS

4.1 No Significant Hazards Consideration Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.90, "Issuance of amendment," as discussed below:

LGS U1&2: Evaluation of Proposed Attachment 1 Changes to Control Rod Requirements Page 6 of 8

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The first proposed change would exclude fully inserted immovable control rods from consideration in the plant shutdown action statement. An inoperable control rod that has been fully inserted, and disarmed, has satisfied the safety function of that control rod since it is in a position of maximum contribution to shutdown capability. A plant shutdown for this situation would result in an unnecessary plant thermal cycle without any compensatory safety benefit. Under the proposed change, inoperable inserted rods would continue to be counted in the operability requirement precluding power operation with more than 8 inoperable control rods.

The second proposed change removes the control rod drive (CRD) water pressure limits from the insertion capability test of inoperable, non-stuck, control rods. Reactor pressure, assisted by a pre-charged accumulator, provides the driving force for the rapid shutdown of the reactor (scram), independent of the CRD water pressure. Variation of this pressure is not an indicator of a degraded control rod, and does not inhibit the safety function of the control rod. Control rod scram and exercise testing requirements assure the operability of the CRD system. The proposed change would eliminate the need to unnecessarily insert a control rod into the core if it could not be repositioned using the normal drive water pressure setting.

The third proposed change would limit the increased frequency surveillance requirement (every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) exercise test of withdrawn control rods upon discovery of an immovable control rod to a one-time test in lieu of every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A one-time 24-hour test is sufficient to determine if a generic control rod problem exists. Under the proposed change, following the 24-hour test, and in the absence of any additional detectible problems, the control rod exercise test would revert back to a normal testing frequency. Repetitive 24-hour tests has the potential to reduce the operable lifespan of hydraulic control unit components and increases the potential for a reactivity management event.

The proposed changes will not impede the ability of the surveillance requirements to detect control rod degradation, or inhibit the control rod drive system from performing its designed safety function.

Therefore, this proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No. The proposed changes do not alter the physical design, safety limits, or safety analysis assumptions, associated with the operation of the plant. Accordingly, the changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant structure, system, or component to perform their safety function.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

LGS U1&2: Evaluation of Proposed Attachment 1 Changes to Control Rod Requirements Page 7 of 8

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No. A fully inserted rod has satisfied its safety function by being in the position of maximum contribution to shutdown reactivity. Eliminating the CRD drive water pressure limits does not impact scram capability. Further, the proposed changes will eliminate extended accelerated control rod testing that may shorten the lifespan of control components without any compromise in the detection of control rod operability problems. The proposed changes would not impact control rod operability and surveillance requirements that are necessary to assure that the control rod system will perform its designed safety function.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that 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.

4.2 Applicable Regulatory Requirements/Criteria The NRC approved document, NUREG-1433, "Standard Technical Specifications - General Electric Plants, BWR/4," Revision 2 (reference 1), identifies an improved standard technical specifications (ISTS) that was developed based on the criteria in the Final Commission Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors, dated July 22, 1993, and subsequently codified in 10 CFR 50.36. The ISTS reflects an industry-NRC consensus of the particular safety functions required to comply with the criteria identified in 10 CFR 50.36. The ISTS (1) does not subject an immovable control rod to a shutdown action, provided the rod is in the fully inserted position, (2) limits the 24-hour accelerated control rod test to a one time requirement, and (3) excludes consideration of the control rod drive pressure during surveillance exercise testing. The changes proposed herein are consistent with these features of the ISTS.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, 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 offsite, or (iii) a significant increase in individual or cumulative occupational radiation

LGS U1&2: Evaluation of Proposed Attachment 1 Changes to Control Rod Requirements Page 8 of 8 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 impact statem6nt or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NUREG-1433, Revision 2, "Standard Technical Specifications-General Electric Plants.

BWR/4," June 2001.

2. Technical Paper No. BWROG-CRD-03-B, Revision 0, "Guideline for Troubleshooting and Freeing Stuck CRDMs," September 2003.
3. Technical Paper No. BWROG-CRD-00-A, Revision 0, "Standard for the Selection of Control Rod Drive Mechanisms for Preventative Maintenance during Refueling Outages,"

September 2000.

4. NUREG/CR-5699, ORNL-6666N1, Vol. 1,"Aging and Service Wear of Control Rod Drive Mechanisms for BWR Nuclear Plants," November 1992.

ATTACHMENT 2 License Amendment Request Limerick Generating Station Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to Control Rod Requirements Technical Specification Marked-Up Pages Unit 1 TS Pages 3/4 1-3 3/4 1-5 Unit2 SPages 3/4 1-3 3/4 1-5

REACTIVITY CONTROL SYSTEMS 3/4.1.3 CONTROL RODS

.) CONTROL ROD OPERABILITY LIMITING CONDITTON FOR OPERATION 3.1.3.1 All control rods and scram discharge volume vent and drain valves shall I be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3*** I ACTION: 10d1 w

a. With one control rod inoperable due to being immovable, as a result of excessive friction or mechanical interference, or known to be untrippable:
  • *_LLJwm-LIYA
1. Within 1 hour: k wtA-W' a) Verify that the inoperableAcontrol rDJ/ withdraws is separated from all other ilnoperable c ntrol rods by at least two control cells in all direction b) Disarm the associated directional control valves** either:
1) Electrically, or
2) 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Restore the inoperaNle conro trod to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at lMast HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
b. With one or more control rods trippable but inoperable for causes other than addressed in ACTION a, above:
1. If the inoperable control rod(s) is withdrawn, within 1 hour:

a) Verify that the inoperable withdrawn control rod(s) is separated from all other inoperable withdrawn control rods by at least two control cells in all directions, and b) Demonstrate the insertion capability of the inoperable with-drawn control rwd(s) by inserting the control rod(s) at least'one notchlby driye water prss"re within the porm4

_ . rngo-

"portin *.

    • May be rearmed intermittently, under administrative control, to permit testing associated with restoring the control rod to OPERABLE status.
      • OPERATIONAL CONDITION 3 is only applicable to the scram discharge volume vent and drain valves. I LIMERICK -,UNIT I 3/4 1-3 Amendment No. 168

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REOUIREMENTS (Continued) 4.1.3.1.2 When above the preset power level of the RWM, all withdrawn control rods not required to have their directional control valves disarmed electrically or hydraulically shall be demonstrated OPERABLE by moving each control rod at least one notch:

a. At least once per 7 days, and M~s~htt Ad our-S i's"Vepy/ ~
b. lAt n per 21 hors n natcontrol 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, 4.1.3.4, 4.1.3.5, 4.1.3.6, and 4.1.3.7.

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

a. The scram discharge volume drain and vent valves OPERABLE at least once per 24 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.
b. Proper level sensor response by performance of a CHANNEL FUNCTIONAL TEST of the scram discharge volume scram and control rod block level instrumentation at least once per 92 days.

LIMERICK - UNIT I 3/4 1-5 Amendment No. 4, 14, 98, 168

REACTIVITY CONTROL SYSTEMS 3/4.1.3 CONTROL RODS CONTROL ROD OPERABILITY LIMITING CONDITION FOR OPERATION 3.1.3.1 All control rods and scram discharge volume vent and drain valves shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3***

ACTION:

a. With one confro`lrod inoperable due to being immovable, as a result of excesive friction or mechanical interference, or known to be untrippable:
1. Within 1 hour:

a) Verify that the inoperable control rId1 i .n/

aw4 is separated from all other inoperable ontrol rods by at least two control cells in all direction b) Disarm the associated directional control -valves** either:

1) Electrically, or
2) 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Restore the inopera co rod to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
b. With one or more control rods trippable but inoperable for causes other than addressed in ACTION a, above:
1. If the inoperable control rod(s) is withdrawn, within 1 hour:

a) Verify that the inoperable withdrawn control rod(s) is separated from all other inoperable withdrawn control rods by at least two control cells in all directions, and b) Demonstrate the insertion capability of the inoperable with-drawn control rod(s) by inserting the control rod(s) at least one notchby-rv; r prcr~uro within threnz e

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

LIMERICK - UNIT 2 3/4 1-3 Amendment No. 131

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)-

4.1.3.1.2 When above the preset power level of the RWM, all withdrawn control rods not required to have their directional control valves disarmed electrically or hydraulically shall be demonstrated OPERABLE by moving each control rod at least one notch:

a. At least once per 7 days, and etos -Wrohz J.coP kobuZ a
b. At lea onec per 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> whtn ant- 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, 4.1.3.4, 4.1.3.5, 4.1.3.6, and 4.1.3.7.

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

a. The scram discharge volume drain and vent valves OPERABLE at least once per 24 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.
b. Proper level sensor response by performance of a CHANNEL FUNCTIONAL TEST of the scram discharge volume scram and control rod block level instrumentation at least once per 92 days.

LIMERICK - UNIT 2 3/4 1-5 Amendment No. 33, 34, b2, 131

ATTACHMENT 3 License Amendment Request Limerick Generating Station Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to Control Rod Requirements Technical Specification Typed Pages ULi T VSPag 3/4 1-3 3/4 1-5 Unit 2 TS Pagses 3/4 1-3 3/4 1-5

REACTIVITY CONTROL SYSTEMS 3/4.1.3 CONTROL RODS CONTROL ROD OPERABILITY LIMJIIINflCOtNDITION FOR OPERATION__

3.1.3.1 All control rods and scram discharge volume vent and drain valves shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3***

ACTION:

a. With one withdrawn control rod inoperable due to being immovable, as a result of excessive friction or mechanical interference, or known to be untrippable:
1. Within 1 hour:

a) Verify that the inoperable withdrawn control rod is separated from all other inoperable withdrawn control rods by at least two control cells in all directions.

b) Disarm the associated directional control valves** either:

1) Electrically, or
2) 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Restore the inoperable withdrawn control rod to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
b. With one or more control rods trippable but inoperable for causes other than addressed in ACTION a, above:
1. If the inoperable control rod(s) is withdrawn, within 1 hour:

a) Verify that the inoperable withdrawn control rod(s) is separated from all other inoperable withdrawn control rods by at least two control cells in all directions, and b) Demonstrate the insertion capability of the inoperable with-drawn control rod(s) by inserting the control rod(s) at least one notch*.

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

LIMERICK - UNIT 1 3/4 1-3 Amendment No. 168

REACTIVITY CONTROL SYSTEMS

.SURVEILLANCE REOUIREMENI .(Continued) 4.1.3.1.2 When above the preset power level of the RWM, all withdrawn control rods not required to have their directional control valves disarmed 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery that a 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, 4.1.3.4, 4.1.3.5, 4.1.3.6, and 4.1.3.7.

4.1.3.1.4 The scram-discharge volume shall be determined OPERABLE by demonstrating:

a. The scram discharge volume drain and vent valves OPERABLE at least once per 24 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.
b. Proper level sensor response by performance of a CHANNEL FUNCTIONAL TEST of the scram discharge volume scram and control rod block level instrumentation at least once per 92 days.

LIMERICK - UNIT 1 3/4 1-5 Amendment No. 70, 7-, 98, 1-6-8,

REACTIVITY CONTROL SYSTEMS

^ 3/4.1.3 CONTROL RODS CONTROL ROD OPERABILITY ILIMITING CONDITION FOR OPERATION 3.1.3.1 All control rods and scram discharge volume vent and drain valves shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3***

ACTION:

a. With one withdrawn control rod inoperable due to being immovable, as a result of excessive friction or mechanical interference, or known to be untrippable:
1. Within 1 hour:

a) Verify that the inoperable withdrawn control rod is separated from all other inoperable withdrawn control rods by at least two control cells in all directions.

b) Disarm the associated directional control valves** either:

1) Electrically, or
2) 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Restore the inoperable control rod to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
b. With one or more control rods trippable but inoperable for causes other than addressed in ACTION a, above:
1. If the inoperable withdrawn control rod(s) is withdrawn, within 1 hour:

a) Verify that the inoperable withdrawn control rod(s) is separated from all other inoperable withdrawn control rods by at least two control cells in all directions, and b) Demonstrate the insertion capability of the inoperable with-drawn control rod(s) by inserting the control rod(s) at least one notch*.

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

LIMERICK - UNIT 2 3/4 1-3 Amendment No. 131

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.1.3.1.2 When above the preset power level of the RWM, all withdrawn control rods not required to have their directional control valves disarmed 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery that a 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, 4.1.3.4, 4.1.3.5, 4.1.3.6, and 4.1.3.7.

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

a. The scram discharge volume drain and vent valves OPERABLE at least once per 24 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.
b. Proper level sensor response by performance of a CHANNEL FUNCTIONAL TEST of the scram discharge volume scram and control rod block level instrumentation at least once per 92 days.

LIMERICK - UNIT 2 3/4 1-5 Amendment No. 33, 34, 62, 4134,