Text

Proposed License Amendment Inoperable Rod Position Indication
	ML042180193
Person / Time
Site:	Turkey Point
Issue date:	07/28/2004
From:	Jones T; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2004-174
	Download: ML042180193 (34)
	v • d • e

FPL L-2004-174 10 CFR 50.90 10 CFR 50.91 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 RE: Turkey Point Unit 4 Docket No. 50-251 Proposed License Amendment Inoperable Rod Position Indication Pursuant to 10 CFR 50.90 and 10 CFR 50.91 (a)(6), Florida Power and Light Company (FPL) requests exigent approval of changes to the Turkey Point Unit 4 Facility Operating License DPR-41 by incorporating the attached Technical Specification (TS) revision. This revision is being requested due to an inoperable control'Rod Position Indicator (RPI). The proposed amendment would revise applicable Technical Specifications to allow the use of an alternate method of determining rod position for the control rod with the inoperable RPI. is an evaluation of the proposed change. Attachment 2 is the "Determination of No Significant Hazards Consideration." Attachments 3 and 4 contain copies of the affected Technical Specifications pages marked-up and a clean copy of the proposed revision, respectively.

The Turkey Point Plant Nuclear Safety Review Committee and the FPL Company Nuclear Review Board have reviewed the proposed amendment. Inaccordance with 10 CFR 50.91 (b)(1), a copy of the proposed amendment is being forwarded to the State Designee for the State of Florida.

FPL is requesting that this amendment be processed as an exigent amendment request pursuant to 10 CFR 50.91 (a)(6). The reason for the exigency is due to the unanticipated failure of the Turkey Point Unit 4 Analog RPI for control rod F-8 in Shutdown Bank B. This RPI has been declared inoperable due to faulty wiring connectors and is not repairable at power; it must be replaced. Additionally, there is concern regarding excessive wear of the movable incore detector system, due to exercising the movable incore detectors every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (90 times per month), to comply with the compensatory actions required by the current action statement a. of TS 3.1.3.2.

This request is similar to the Turkey Point Unit 4 Exigent Technical Specification Amendment request submitted by FPL letter L-2002-152, dated July 29, 2002 and approved by NRC on August 20, 2002 (TAC No. MB5703). During the most recent Unit 4 refueling outage, all Unit 4 RPI connectors were inspected and tested. Faulty RPI connector C-9 and one other faulty connector was replaced at that time.

an FPL Group company

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Page 2 Proposed License Amendment Inoperable Rod Position Indication The failure of the RPI for control rod F-8 resulted in erratic position indication from 230 steps to 30 steps, with Shutdown Bank B all rods out position at 230 steps.

Troubleshooting activities outside containment have indicated that the erratic position indication is due to issues with the connections at the RPI detector or at the bulkhead connector inside containment. Attempts to repair the connectors have been unsuccessful; replacement of the associated wiring and connectors is required to effect a permanent resolution to the erratic position indication. These issues can not be worked during power operations. For the plant to conduct a shutdown to Mode 5 to repair the inoperable RPI at this time would unnecessarily result in an undesirable plant transient. Repairs will be performed at the earliest opportunity, when Turkey Point Unit 4 enters Mode 5 and the outage is of sufficient duration to effect the repairs, but no later than Unit 4 Cycle 22 refueling outage in Spring, 2005.

With one analog rod position indicator inoperable, action statement a. of TS 3.1.3.2 currently requires that 1.) Determine the position of the non-indicating rod(s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and within one hour after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or 2.) Reduce THERMAL POWER to less than 75% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

FPL is currently implementing TS action statement a.1. Implementation of the request contained in this submittal will allow the use of an alternate method of determining rod position for the control rod with the inoperable RPI. The method to be used will monitor the stationary gripper coil of the F-8 Control Rod Drive Mechanism (CRDM). This alternate method is applied to the inoperable F-8 RPI in the following TS sections and associated Surveillance Requirements:

3/4.1.3.1, Movable Control Assemblies 3/4.1.3.2, Position Indicating Systems - Operating 3/4.1.3.5, Shutdown Rod Insertion Limit The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1), using the criteria in 10CFR50.92(c). FPL has determined that the proposed changes involve no significant hazards considerations.

Permanent resolution of the RPI detector connection problem includes replacement/upgrade of RPI cabling and connectors during the upcoming refueling outages in the Fall of 2004 and in the Spring of 2005 for Turkey Point Units 3 and 4, respectively.

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Page 3 Proposed License Amendment Inoperable Rod Position Indication Upon approval of the proposed change, FPL requests that the amendment be made effective on the date of issuance.

Please contact Walter Parker, Licensing Manager, at (305) 246-6632, if there are any questions regarding this submittal.

Very truly your Vie Terry 0. ones Vice President Turkey Point Plant SM Attachments cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Mr. W. A. Passetti, Florida Department of Health

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Page 4 Proposed License Amendment Inoperable Rod Position Indication STATE OF FLORIDA )

) ss.

COUNTY OF MIAMI-DADE )

Terry 0. Jones being first duly sworn, deposes and says:

That he is Vice President, Turkey Point Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

TerrO.Jones STATE OF FLORIDA COUNTY OF Miami-Dade Sworn to and subscribed before me this day of 'Jcae 4 , 2004 by, Terry 0. Jones who is personally known to me.

Signature of Notary Public-State of Florida

% DARIUS D.REID

,4+* *'t~Notary Public - State of Florida

-.*1: )*.1 -MyCommssk~n ExoiresJlna 232007

', ' Commission # DD156688 Bonded By Notional NOtoryAssn.

Nan .9vyvzbi64ej 1i - r Stamp)

Turkey Point Unit 4 L-2004-1 74 Docket No. 50-251 Attachment 1 Proposed License Amendment Page 1 of 6 Inoperable Rod Position Indication EVALUATION OF PROPOSED TS CHANGE

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Attachment 1 Proposed License Amendment Page 2 of 6 Inoperable Rod Position Indi6ation EVALUATION OF PROPOSED TS CHANGE BACKGROUND This request is similar to the Turkey Point Unit 4 Exigent Technical Specification Amendment request submitted by FPL letter L-2002-152, dated July 29, 2002 and approved by NRC on August 20, 2002 (TAC No. MB5703). At that time, the Unit 4 RPI for control rod C-9 in Shutdown Bank A was faulty and the proposed alternate rod position monitoring method was approved for Turkey Point Unit 4 under License Amendment 216.

During the subsequent Unit 4 refueling outage, it was determined that the fault on control rod C-9 was due to insufficient pin contact engagement on one pin of the multi-pin connector. The associated Rod Position Indicator (RPI) wiring and connectors for control rod C-9 were replaced. At the same time, to evaluate the extent of connector degradation in the RPI system, a 100 percent inspection of all other Unit 4 RPI connectors was performed. This resulted in the further replacement of one additional RPI connector. The RPI connector for control rod F-8 was not identified at that time as requiring replacement.

The as-left condition of the RPI system was resistance checked to verify complete connector continuity. Complete RPI wiring and connector system replacement was not considered justified at that time, since replacement of RPI wiring and connectors with a new design was planned during the next extended reactor vessel head replacement refueling outage for both Unit 3 and Unit 4. All necessary resources and materials have been procured to perform these replacements.

Pursuant to 10 CFR 50.90 and 10 CFR 50.91 (a)(6), Florida Power and Light Company (FPL) requests that Turkey Point Unit 4 Technical Specification (TS) 3/4.1.3.1, 3/4.1.3.2 and 3/4.1.3.5 be modified to allow the use of an alternate method of determining rod position for F-8 control rod with the inoperable RPI. This would be effective until repair of the indication system can be completed.

The failure of the RPI for control rod F-8 resulted in erratic position indication from 230 steps to 30 steps, with Shutdown Bank B all rods out position at 230 steps.

Troubleshooting activities outside containment have indicated that the erratic position indication is due to issues with the connections at the RPI detector or at the bulkhead connector inside containment. Attempts to repair the connectors have been unsuccessful; replacement of the associated wiring and connectors is required to effect a permanent resolution to the erratic position indication. These issues can not be worked during power operations. For the plant to conduct a shutdown to Mode 5 to repair the inoperable RPI at this time would unnecessarily result in an undesirable plant transient. Repairs will be performed at the earliest opportunity, when Turkey Point Unit 4 enters Mode 5 and the outage is of sufficient duration to effect the repairs, but no later than Unit 4 Cycle 22 refueling outage currently scheduled for Spring 2005.

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Attachment 1 Proposed License Amendment,- Page 3 of 6 Inoperable Rod Position Indication The proposed changes provide adequate controls to ensure that the rod position is known and to ensure that a rod drop or misalignment is detectable. The justification of the requested changes concludes that the increase in the likelihood of an undetected rod drop or misalignment is negligible and that the basis and consequences of the accident analyses are maintained.

DESCRIPTION OF PROPOSED TS CHANGE The current Technical Specifications were previously revised with Exigent Technical Specification Amendment dated August 20, 2002, concerning the inoperability of Rod Position Indication System for Control Rod C-9 in Shutdown Bank A, limited to Unit 4 operating Cycle 20 only. The RPI system for C-9 was repaired during Unit 4 refueling operations; thus, the associated TS revisions are no longer in effect. The TSs have not yet been revised to remove the associated notes regarding the inoperability of control rod C-9 in Shutdown Bank A.

The proposed Unit 4 Technical Specification changes regarding control rod F-8 in Shutdown Bank B, including the removal of the notes for control rod C-9 in Shutdown Bank A, are summarized below. Marked-up and clean Technical Specification pages for the proposed changes are provided as Attachments 3 and 4.

With one analog rod position indicator inoperable, TS action statement a. of TS 3.1.3.2 currently requires that 1.) Determine the position of the non-indicating rod(s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and within one hour after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or 2.) Reduce THERMAL POWER to less than 75% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . FPL is currently implementing action statement a.1. A description of the proposed changes is provided below.

For TS 3/4.1.3.1, Movable Control Assemblies, 3/4.1.3.2, Position Indicating Systems -

Operating, and 3/4.1.3.5, Shutdown Rod Insertion Limit, the existing note regarding the position of Rod C-9 is removed, and the following note is added to sections relating to the use of analog rod position indication:

"During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

For Surveillance Requirement of 4.1.3.1.1, the existing note regarding the position of Rod C-9 is removed, and the following note is added regarding the use of analog rod position indication:

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Attachment 1 Proposed License Amendment . Page 4 of 6 Inoperable Rod Position Indication "During Unit 4 Cycle 21, the position of Rod F-8, Shutdown Bank B, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod F-8 does not require the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months comparison of demanded versus actual position per 4.1.3.1.1."

Additionally, for Surveillance Requirements of 4.1.3.2.1, the existing note for Rod C-9 is removed, and the following note is added regarding the use of analog rod position indication:

"During Unit 4 Cycle 21, the position of Rod F-8, Shutdown Bank B, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod F-8 does not require the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months comparison of demanded versus actual position per 4.1.3.2.1."

JUSTIFICATION FOR PROPOSED TS CHANGE As described in the bases for Specification 3.1.3, the purpose of the rod control system, of which the RPls are an integral part, is to ensure that: "(1) acceptable power distribution limits are maintained, (2) the minimum SHUTDOWN MARGIN is maintained, and (3) the potential effects of rod misalignment on associated accident analyses are limited.

OPERABILITY of the control rod position indicators is required to determine control rod positions and thereby ensure compliance with the control rod alignment and insertion limits."

FPL has determined that these objectives can be met with an inoperable RPI in a shutdown bank without subjecting the movable incore system to unnecessary additional wear. FPL will install a recorder to track parameters of the stationary gripper coil of the Control Rod Drive Mechanism (CRDM) on the non-indicating rod; FPL will verify at least once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months that the coil has not changed state. This 8-hour surveillance period is consistent with the current operational requirements for control rod F-8 flux trace position determination. Ifthe coil has changed state, a determination of control rod F-8 position will be made by using the movable incore detector system in accordance with plant procedures. At least once every 31 effective full power days, a determination of control rod F-8 position will be made, using the movable incore system.

In summary, FPL concludes that the proposed change will ensure that the intent of Technical Specifications are met.

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Attachment 1 Proposed License Amendment,. Page 5 of 6 Inoperable Rod Position lndication In evaluating the requested change, the following conditions were considered:

Rod Drop or Rod Misalignment During Power Operation

Rod Drop or Rod Misalignment During Reactor Startup

Reactor Trip Rod Drop or Rod Misalignment During Power Operation A full rod drop of this control rod would be immediately detectable by other means than the position indication system. Independent indication of a dropped control rod is obtained by using the excore power range signals. This rod drop detection circuit is actuated upon sensing a rapid decrease in flux and is designed such that normal load variations do not cause it to be actuated. Furthermore, a negative reactivity insertion corresponding to the reactivity worth of a full rod drop of control rod F-8 would cause a noticeable change in core parameters including core power and core average temperature.

A rod misalignment of this control rod may also be detectable by other means, e.g. axial flux deviation and the required operator actions would therefore not be dependent on the status of the individual rod position indication system.

The Shutdown Margin Calculation procedure O-OP-028.2 will be revised to ensure that shutdown margin limits continue to be met for the remainder of this operating cycle. The use of the alternate methodology requires that the pertinent procedures are modified to account for the inoperable RPI. Additional training including operator simulator training with the instrumentation required for the alternate methodology will be provided to the reactor operators and Instrumentation and Control Maintenance technicians to assure familiarity with new plant conditions and modified procedures.

With alternate CRDM parameter monitoring and rod drop/misalignment parameter indications, the increase in the likelihood of an undetected rod drop or misalignment is considered to be negligible.

Rod Drop or Misalignment During Reactor Startup Since the movable incore detectors cannot be used to determine rod position until sometime after entry into Mode 2, when neutron flux becomes adequate, an alternate method will be utilized during a reactor startup to provide initial verification that Rod F-8 is fully withdrawn. This alternate method would only be used as a means of verifying rod position if the startup occurs as a result of an unplanned outage that does not permit repair of the indicating circuit. The proposed alternate method would be utilized to verify that the rod is fully withdrawn. Rod position verification using this method will permit startup and entry into Mode 2. As a second diverse check, the movable incore detectors will be used to verify rod position when neutron flux becomes adequate. Following verification that the rod is withdrawn, a rod misalignment would be detectable by means other than the rod

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Attachment 1 Proposed License Amendment Page 6 of 6 Inoperable Rod Position Indication position indication system, e.g. CRDM trace monitoring, axial flux deviation and the required operator actions would therefore not be dependent on the status of the individual rod position indication.

The increase in the likelihood of an undetected rod drop or misalignment is therefore considered to be negligible.

Reactor Trip Following a reactor trip, the position indication system is used to verify that all rods have fully inserted. Emergency boration is required if more than one rod fails to fully insert. The inoperability of the position indication system prevents verification of insertion for the subject rod during a reactor trip. Administrative controls will be used to heighten reactor operator awareness that the rod position indication for Rod F-8 is inoperable. This will ensure that emergency boration is initiated as required if another control rod other than F-8 does not fully insert.

Turkey Point Unit 4 L-2004-1 74 Docket No. 50-251 Attachment 2 Proposed License Amendment Page 1 of 3 Inoperable Rod Position Indication DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Attachment 2 Proposed License Amendment - Page 2 of 3 Inoperable Rod Position Indication DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Florida Power and Light Company (FPL) has concluded that the proposed amendment to the Turkey Point Unit 4 operating license does not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The proposed change provides an alternative method for verifying rod position of one shutdown rod. The proposed change meets the intent of the current specification in that it ensures verification of position of the control rod once every eight (8) hours. The proposed change provides only an alternative method of monitoring shutdown rod position and does not change the assumption or results of any previously evaluated accident.

Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

No. As described above, the proposed change provides only an alternative method of determining the position of one shutdown rod. No new accident initiators are introduced by the proposed alternative manner of performing rod position verification. The proposed change does not affect the reactor protection system or the reactor control system. Hence, no new failure modes are created that would cause a new or different kind of accident from any accident previously evaluated.

Therefore, operation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any previously evaluated.

Turkey Point Unit 4 L-2004-174 Docket No. 50-251 Attachment 2 Proposed License Amendment . Page 3 of 3 Inoperable Rod Position Indication

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

No. The bases of Specification 3.1.3.2 state that the operability of the rod position indicators is required to determine control rod positions and thereby ensure compliance with the control rod alignment and insertion limits. The proposed change does not alter the requirement to determine rod position but provides an alternative method for determining the position of the affected rod. As a result, the initial conditions of the accident analysis are preserved and the consequences of previously analyzed accidents are unaffected.

Therefore, operation of the facility in accordance with the proposed amendments would not involve a significant reduction in the margin of safety.

Based on the reasoning presented above, FPL has determined that the requested changes involve no significant hazards consideration.

Environmental Consideration The proposed license amendment changes requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

The proposed amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. FPL concluded that the proposed amendment involves no significant hazards consideration and meets the criteria for categorical exclusion set forth in 10 CFR 51 .22(c)(9) and that, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.

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

Turkey Point Unit 4 L-2004-1 74 Docket No. 50-251 Attachment 3 Proposed License Amendment Page 1 of 1 Inoperable Rod Position Indication TURKEY POINT UNIT 4 MARKED UP TECHNICAL SPECIFICATION PAGES Pages 3/4 1-17 Pages 3/4 1-18 Pages 3/4 1-20 Pages 3/4 1-21 Pages 3/4 1-25

Turkey Point Unit 4 L-2004-1 74 Docket No. 50-251 Attachment 4 Proposed License Amendment Page 1 of 1 Inoperable Rod Position Indication TURKEY POINT UNIT 4 CLEAN TECHNICAL SPECIFICATION PAGES Pages 3/4 1-17 Pages 3/4 1-18 Pages 3/4 1-20 Pages 3/4 1-21 Pages 3/4 1-25

i.

Turkey Point Unit 4 L-2004-1 74 Docket No. 50-251 Attachment 3 Proposed License Amendment Page 1 of 1 Inoperable Rod Position Indication TURKEY POINT UNIT 4 MARKED UP TECHNICAL SPECIFICATION PAGES Pages 3/4 1-17 Pages 3/4 1-18 Pages 3/4 1-20 Pages 3/4 1-21 Pages 3/4 1-25

REACTIVITY CONTROL SYSTEMS 3/4.1.3 MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPERATION 3.1.3.1 All full length (shutdown and control) rods shall be OPERABLE and positioned within the Allowed Rod Misalignment between the Analog Rod Position Indication ** and the group step counter demand position within one hour after rod motion. The Allowed Rod Misalignment shall be defined as:

a. for THERMAL POWER less than or equal to 90% of RATED THERMAL POWER, the Allowed Rod Misalignment is +/- 18 steps, and

b. for THERMAL POWER greater than 90% of RATED THERMAL POWER, the Allowed Rod Misalignment is+/- 12 steps.

APPLICABILITY: MODES 1* and 2*

ACTION:

a. With one or more full length rods inoperable due to being immovable as a result of excessive friction or mechanical interference or known to be untrippable, determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With more than one full length rod inoperable or misaligned from the group step counter demand position by more than +/- 12 steps and THERMAL POWER greater than 90% of RATED THERMAL POWER, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either:

1. Restore all indicated rod positions to within the Allowed Rod Misalignment, or

2. Reduce THERMAL POWER to less than 90% of RATED THERMAL POWER and confirm that all indicated rod positions are within the Allowed Rod Misalignment, or

3. Be in HOT STANDBY within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With more than one full length rod inoperable or misaligned from the group step counter demand position by more than +/- 18 steps and THERMAL POWER less than or equal to 90% of RATED THERMAL POWER, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either:

1. Restore all Indicated rod positions to within the Allowed Rod Misalignment, or

2. Be in HOT STANDBY within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

I See Special Test Exceptions 3.10.2 and 3.10.3 _

igUos i o o Shutdown Bank A will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed, until the repair of the indication system for this rod is completed.

t o \I -A TURKEY POINT - UNITS 3 & 4 3/4 1-17 AMENDMENT NOS. 186 ANDY24

INSERT A uDuring Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

d. With one full length rod inoperable due to causes other than addressed by ACTION a, above, or misaligned from its group step counter demand position by more than the Allowed Rod Misalignment of Specification 3.1.3.1, POWER OPERATION may continue provided that within one hour either:

1. The rod is restored to OPERABLE status within the Allowed Rod Misalignment of Specification 3.1.3.1, or

2. The remainder of the rods in the bank with the inoperable rod are aligned to within the Allowed Rod Misalignment of Specification 3.1.3.1 of the inoperable rod while maintaining the rod sequence and insertion limits of Specification 3.1.3.6; the THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation, or

3. The rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:

a) The THERMAL POWER level is reduced to less than or equal to 75% of RATED THERMAL POWER within one hour and within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the power range neutron flux high trip setpoint is reduced to less than or equal to 85% of RATED THERMAL POWER. THERMAL POWER shall be maintained less than or equal to 75% of RATED THERMAL POWER until compliance with ACTIONS 3.1.3.1.d.3.c and 3.1.3.1.d.3.d below are demonstrated, and b) The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and c) A power distribution map is obtained from the movable incore detectors and F0 (Z) and FN Hare verified to be within their limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and d) A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions.

SURVEILLANCE REQUIREMENTS 4.1.3.1.1 The position

of each full length rod shall be determined to be within the Allowed Rod Misalignment of l the group step counter demand position at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (allowing for one hour thermal soak after rod motion) except during time invervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ** I 4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction at least once per 92 days.

Dung i ce p0 ion Rod C-9 Shutdown Bank A will be determined every 6 houirs by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed.

- During Unit 4 Cycle 20, the position of rod C-9, Shutdown Bank A, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod C-9 does not Dt* aPsrA ^ ADws£Q- B TURKEY POINT- UNITS 3 & 4 3/4 1-18 AMENDMENT NOS. 186 AND 24% l

INSERT A

'During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

INSERT B

'During Unit 4 Cycle 21, the position of rod F-8, Shutdown Bank B, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod F-8 does not require the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months comparison of demanded versus actual position per 4.1.3.1.1."

REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION (Continued) 3.1.3.2 The Analog Rod Position Indication System

and the Demand Position Indication System shall be OPERABLE and capable of determining the respective actual and demanded shutdown and control rod positions as follows:

a. Analog rod position indicators *, within one hour after rod motion (allowance for thermal soak);

All Shutdown Banks: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.

Control Bank A and B: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.

Control Banks C and D: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal range of 0-All Rods Out as defined in the Core Operating Limits Report.

b. Group demand counters; +/- 2 steps.

APPLICABILITY: MODES 1 and 2.

ACTION:

a. With a maximum of one analog rod position indicator

per bank inoperable either

1. Determine the position of the non-indicating rod(s)

indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and within one hour after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or

2. Reduce THERMAL POWER to less than 75% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b. With a maximum of one demand position indicator per bank inoperable either

1. Verify that all analog rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within the Allowed Rod Misalignment of Specification 3.1.3.1 at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or

2. Reduce THERMAL POWER to less than 75% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

uringiUiit 4 Cycie uie position of Rod C-9 Shutdown Bank A will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed.

-[A D D~ 1 TURKEY POINT - UNITS 3 & 4 3/4 1-20 AMENDMENT NOS. 186 AND 246

INSERT A "During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.3.2.1 Each analog rod position indicator

shall be determined to be OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System

agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time Intervals when the Rod Position Deviation Monitor ** is inoperable, then compare the l Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

4.1.3.2.2 Each of the above required analog rod position indicator(s)

shall be determined to be OPERABLE l by performance of a CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST performed in accordance with Table 4.1-1.

l ~every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, untol the repair of the Indication system for this rod Is completed.\

- During Unit 4 Cycle 20, the position of rod C-9, Shutdown Bank A, may be monitored\

by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod C-9 does not require rison of dmnevessatlpoItope4132..

S T TURKEY POINT - UNITS 3 8 4 3/4 1-21 AMENDMENT NOS. 186 AND 246

INSERT A "During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

INSERT C "During Unit 4 Cycle 21, the position of rod F-8, Shutdown Bank B, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod F-8 does not require the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months comparison of demanded versus actual position per 4.1.3.2.1."

REACTIVITY CONTROL SYSTEMS SHUTDOWN ROD INSERTION LIMIT LIMITING CONDITION FOR OPERATION 3.1.3.5 All shutdown rods shall be fully withdrawn.

APPLICABILITY: MODES 1* and 2* **

ACTION:

With a maximum of one shutdown rod not fully withdrawn, except for surveillance testing pursuant to Specification 4.1.3.1.2, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either

a. Fully withdraw the rod, or

b. Declare the rod to be inoperable and apply Specification 3.1.3.1.

SURVEILLANCE REQUIREMENTS 4.1.3.5 Each shutdown rod *** shall be determined to be fully withdrawn:

a. Within 15 minutes prior to withdrawal of any rods in control banks A, B. C, or D during an approach to reactor criticality, and

b. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter.

See Special Test Exceptions Specifications 3.10.2 and 3.10.3.

utdown Bank A will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed./

TURKEY POINT - UNITS 3 8 4 3/4 1-25 AMENDMENT NOS. 137 AND 246-

INSERT A "During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

Turkey Point Unit 4 L-2004-1 74 Docket No. 50-251 Attachment 4 Proposed License Amendment Page 1 of 1 Inoperable Rod Position Indication TURKEY POINT UNIT 4 CLEAN TECHNICAL SPECIFICATION PAGES Pages 3/4 1-17 Pages 3/4 1-18 Pages 3/4 1-20 Pages 3/4 1-21 Pages 3/4 1-25

REACTIVITY CONTROL SYSTEMS 3/4.1.3 MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPERATION 3.1.3.1 All full length (shutdown and control) rods shall be OPERABLE and positioned within the Allowed Rod Misalignment between the Analog Rod Position Indication ** and the group step counter demand position within one hour after rod motion. The Allowed Rod Misalignment shall be defined as:

a. for THERMAL POWER less than or equal to 90% of RATED THERMAL POWER, the Allowed Rod Misalignment is +/- 18 steps, and

b. for THERMAL POWER greater than 90% of RATED THERMAL POWER, the Allowed Rod Misalignment is +/- 12 steps.