ML14339A723

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Technical Specification Bases 3-1-4
ML14339A723
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 11/04/2014
From:
Duke Energy Carolinas
To:
Office of Nuclear Reactor Regulation
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MNS-14-088
Download: ML14339A723 (9)


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Rod Group Alignment Limits B 3.1.4 McGuire Units 1 and 2 B 3.1.4-1 Revision No. 115 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.4 Rod Group Alignment Limits BASES BACKGROUND The OPERABILITY (e.g., trippability) of the shutdown and control rods is an initial assumption in all safety analyses that assume rod insertion upon reactor trip. Maximum rod misalignment is an initial assumption in the safety analysis that directly affects core power distributions and assumptions of available SDM.

The applicable criteria for these reactivity and power distribution design requirements are 10 CFR 50, Appendix A, GDC 10, "Reactor Design,"

GDC 26, "Reactivity Control System Redundancy and Protection" (Ref. 1), and 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Plants" (Ref. 2).

Mechanical or electrical failures may cause a control rod to become inoperable or to become misaligned from its group. Control rod inoperability or misalignment may cause increased power peaking, due to the asymmetric reactivity distribution and a reduction in the total available rod worth for reactor shutdown. Therefore, control rod alignment and OPERABILITY are related to core operation in design power peaking limits and the core design requirement of a minimum SDM.

Limits on control rod alignment have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.

Rod cluster control assemblies (RCCAs), or rods, are moved by their control rod drive mechanisms (CRDMs). Each CRDM moves its RCCA one step (approximately 5/8 inch) at a time, but at varying rates (steps per minute) depending on the signal output from the Rod Control System.

The RCCAs are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that are electrically paralleled to step simultaneously. A bank of RCCAs consists of two groups that are moved in a staggered fashion, but always within one step of each other. The unit has four control banks and five shutdown banks.

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-2 Revision No. 115 BACKGROUND (continued)

The shutdown banks are maintained either in the fully inserted or fully withdrawn position. The control banks are moved in an overlap pattern as described in the Bases for LCO 3.1.6, "Control Bank Insertion Limits." The control rods are arranged in a radially symmetric pattern, so that control bank motion does not introduce radial asymmetries in the core power distributions.

The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which are the Bank Demand Position Indication System (commonly called group step counters) and the Digital Rod Position Indication (DRPI) System.

The Bank Demand Position Indication System counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise (+/- 1 step or +/- 5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.

The DRPI System provides a highly accurate indication of actual control rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center to center distance of 3.75 inches, which is six steps. To increase the reliability of the system, the inductive coils are connected alternately to data system A or B. Thus, if one system fails, the DRPI will go on half-accuracy with an effective coil spacing of 7.5 inches, which is 12 steps. Therefore, the normal indication accuracy of the DRPI System is +/- 6 steps (+/- 3.75 inches), and the maximum uncertainty is

+/- 12 steps (+/- 7.5 inches). With an indicated deviation of 12 steps between the group step counter and DRPI, the maximum deviation between actual rod position and the demand position could be 24 steps, or 15 inches.

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-3 Revision No. 115 APPLICABLE Control rod misalignment accidents are analyzed in the safety analysis SAFETY ANALYSES (Ref. 3). The acceptance criteria for addressing control rod inoperability or misalignment are that:

a.

There be no violations of:

1.

specified acceptable fuel design limits, or

2.

Reactor Coolant System (RCS) pressure boundary integrity; and

b.

The core remains subcritical after accident transients.

Two types of misalignment are distinguished. During movement of a control rod group, one rod may stop moving, while the other rods in the group continue. This condition may cause excessive power peaking.

The second type of misalignment occurs if one rod fails to insert upon a reactor trip and remains stuck fully withdrawn. This condition requires an evaluation to determine that sufficient reactivity worth is held in the control rods to meet the SDM requirement, with the maximum worth rod stuck fully withdrawn.

Analyses are performed in regard to static rod misalignment, single rod withdrawal, dropped rod, and dropped group of rods (Ref. 4). With control banks at their insertion limits, one type of analysis considers the case when any one rod is completely inserted into the core. The second type of analysis considers the case of a completely withdrawn single rod from a bank inserted to its insertion limit. Satisfying limits on departure from nucleate boiling ratio in both of these cases bounds the situation when a rod is misaligned from its group by 12 steps. Another type of misalignment occurs if one RCCA fails to insert upon a reactor trip and remains stuck fully withdrawn. This condition is assumed in the evaluation to determine that the required SDM is met with the maximum worth RCCA also fully withdrawn (Ref. 5).

The Required Actions in this LCO ensure that either deviations from the alignment limits will be corrected or that THERMAL POWER will be adjusted so that excessive local linear heat rates (LHRs) will not occur, and that the requirements on SDM and ejected rod worth are preserved.

Continued operation of the reactor with a misaligned control rod is allowed if the heat flux hot channel factor (FQ(X,Y,Z)) and the nuclear enthalpy hot channel factor (FN H(X,Y)) are verified to be within their limits in the COLR and the safety analysis is verified to remain valid.

When a control rod is misaligned, the assumptions that are used to determine the rod insertion limits, AFD limits, and quadrant power tilt limits are not preserved. Therefore, the limits may not preserve the

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-4 Revision No. 115 APPLICABLE SAFETY ANALYSES (continued) design peaking factors, and FQ(X,Y,Z) and FNH(X,Y) must be verified directly by incore mapping. Bases Section 3.2 (Power Distribution Limits) contains more complete discussions of the relation of FQ(X,Y,Z) and FNH(X,Y) to the operating limits.

Shutdown and control rod OPERABILITY and alignment are directly related to power distributions and SDM, which are initial conditions assumed in the safety analyses. Therefore they satisfy Criterion 2 of 10 CFR 50.36 (Ref. 6).

LCO The requirements on rod OPERABILITY ensure that upon reactor trip, the assumed reactivity will be available and will be inserted. The limits on shutdown and control rod alignments ensure that the assumptions in the safety analysis will remain valid, and that the RCCAs and banks maintain the correct power distribution and rod alignments.

The requirement to maintain the alignment of any one rod to within plus or minus 12 steps is conservative. The minimum misalignment assumed in safety analysis is 24 steps (15 inches), and in some cases a total misalignment from fully withdrawn to fully inserted is assumed. Failure to meet the requirements of this LCO may produce unacceptable power peaking factors and LHRs, or unacceptable SDMs, all of which may constitute initial conditions inconsistent with the safety analysis.

APPLICABILITY The requirements on RCCA OPERABILITY and alignment are applicable in MODES 1 and 2 because these are the only MODES in which neutron (or fission) power is generated, and the OPERABILITY (i.e., trippability) and alignment of rods have the potential to affect the safety of the plant. In MODES 3, 4, 5, and 6, the alignment limits do not apply because the control rods are normally bottomed and the reactor is shut down and not producing fission power. In the shutdown MODES, the OPERABILITY of the shutdown and control rods has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the RCS. See LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

for SDM in MODES 3, 4, and 5 and LCO 3.9.1, "Boron Concentration," for boron concentration requirements during refueling.

ACTIONS A.1.1 and A.1.2 When one or more rods are untrippable, there is a possibility that the required SDM may be adversely affected. Under these conditions, it is

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-5 Revision No. 115 ACTIONS (continued) important to determine the SDM, and if it is less than the required value, initiate boration until the required SDM is recovered. The Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is adequate for determining SDM and, if necessary, for initiating boration to restore SDM.

In this situation, SDM verification must include the worth of the untrippable rod, as well as a rod of maximum worth.

A.2 If the untrippable rod(s) cannot be restored to OPERABLE status, the plant must be brought to a MODE or condition in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The allowed Completion Time is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

B.1 When a rod becomes misaligned, it can usually be moved and is still trippable. If the rod can be realigned within the Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and the rod was not misaligned for a significant period of time before being discovered, local xenon redistribution during this short interval will not be significant, and operation may proceed without further restriction.

An alternative to realigning a single misaligned RCCA to the group average position is to align the remainder of the group to the position of the misaligned RCCA. However, this must be done without violating the bank sequence, overlap, and insertion limits specified in LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits." The Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> gives the operator sufficient time to adjust the rod positions in an orderly manner.

B.2.1.1 and B.2.1.2 With a misaligned rod, SDM must be verified to be within limit or boration must be initiated to restore SDM to within limit.

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-6 Revision No. 115 ACTIONS (continued)

In many cases, realigning the remainder of the group to the misaligned rod may not be desirable. For example, realigning control bank B to a rod that is misaligned 15 steps from the top of the core would require a significant power reduction, since control bank D must be moved fully in and control bank C must be moved in to approximately 100 to 115 steps.

Power operation may continue with one RCCA trippable but misaligned, provided that SDM is verified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

The Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> represents the time necessary for determining the actual unit SDM and, if necessary, aligning and starting the necessary systems and components to initiate boration.

B.2.2, B.2.3, B.2.4, B.2.5, and B.2.6 For continued operation with a misaligned rod, RTP must be reduced, SDM must periodically be verified within limits, hot channel factors FQ(X,Y,Z) and FNH(X,Y) must be verified within limits, and the safety analyses must be re-evaluated to confirm continued operation is permissible.

Reduction of power to 75% RTP ensures that local LHR increases due to a misaligned RCCA will not cause the core design criteria to be exceeded (Ref. 7). The Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> gives the operator sufficient time to accomplish an orderly power reduction without challenging the Reactor Protection System.

When a rod is known to be misaligned, there is a potential to impact the SDM. Since the core conditions can change with time, periodic verification of SDM is required. A Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is sufficient to ensure this requirement continues to be met.

Verifying that FQ(X,Y,Z) and FNH(X,Y) are within the required limits ensures that current operation at 75% RTP with a rod misaligned is not resulting in power distributions that may invalidate safety analysis assumptions at full power. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allows sufficient time to obtain flux maps of the core power distribution using the incore flux mapping system and to calculate FQ(X,Y,Z) and FNH(X,Y).

Once current conditions have been verified acceptable, time is available to perform evaluations of accident analysis to determine that core limits will not be exceeded during a Design Basis Event for the duration of

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-7 Revision No. 115 ACTIONS (continued) operation under these conditions. A Completion Time of 5 days is sufficient time to obtain the required input data and to perform the analysis.

C.1 When Required Actions cannot be completed within their Completion Time, the unit must be brought to a MODE or Condition in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, which obviates concerns about the development of undesirable xenon or power distributions. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging the plant systems.

D.1.1 and D.1.2 More than one control rod becoming misaligned from its group average position is not expected, and has the potential to reduce SDM. Therefore, SDM must be evaluated. One hour allows the operator adequate time to determine SDM. Restoration of the required SDM, if necessary, requires increasing the RCS boron concentration to provide negative reactivity, as described in the Bases or LCO 3.1.1. The required Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for initiating boration is reasonable, based on the time required for potential xenon redistribution, the low probability of an accident occurring, and the steps required to complete the action. This allows the operator sufficient time to align the required valves and start the boric acid pumps.

Boration will continue until the required SDM is restored.

D.2 If more than one rod is found to be misaligned or becomes misaligned because of bank movement, the unit conditions fall outside of the accident analysis assumptions. The unit must be brought to a MODE or Condition in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The allowed Completion Time is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-8 Revision No. 115 SURVEILLANCE SR 3.1.4.1 REQUIREMENTS The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. If the rod position deviation monitor is inoperable, a Frequency of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is required.

SR 3.1.4.2 Verifying each control rod is OPERABLE would require that each rod be tripped. However, in MODES 1 and 2, tripping each control rod would result in radial or axial power tilts, or oscillations.

Exercising each individual control rod provides increased confidence that all rods continue to be OPERABLE without exceeding the alignment limit, even if they are not regularly tripped.

Moving each control rod by 10 steps will not cause radial or axial power tilts, or oscillations, to occur. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. Between required performances of SR 3.1.4.2 (determination of control rod OPERABILITY by movement), if a control rod(s) is discovered to be immovable, but remains trippable and aligned, the control rod(s) is considered to be OPERABLE. At any time, if a control rod(s) is immovable, a determination of the trippability (OPERABILITY) of the control rod(s) must be made, and appropriate action taken. This may be by verification of a control system failure, usually electrical in nature, or that the failure is associated with the control rod stepping mechanism. During performance of the Control Rod Movement periodic test, there have been some "Control Malfunctions" that prohibited a control rod bank or group from moving when selected, as evidenced by the demand counters and DRPI. In all cases, when the control malfunctions were corrected, the rods moved freely (no excessive friction or mechanical interference) and were trippable.

SR 3.1.4.3 Verification of rod drop times allows the operator to determine that the maximum rod drop time permitted is consistent with the assumed rod drop time used in the safety analysis. Since a removal of the reactor vessel head has the potential to change component alignments affecting

Rod Group Alignment Limits B 3.1.4 BASES McGuire Units 1 and 2 B 3.1.4-9 Revision No. 115 SURVEILLANCE REQUIREMENTS (continued) rod drop times, measuring drop times prior to the next criticality following any such removal ensures that the reactor internals and rod drive mechanism will not interfere with rod motion or rod drop time, and that no degradation in these systems has occurred that would adversely affect control rod motion or drop time. This testing is performed with all RCPs operating and the average moderator temperature 551°F to simulate a reactor trip under actual conditions.

This Surveillance is performed during a plant outage, due to the plant conditions needed to perform the SR and the potential for an unplanned plant transient if the Surveillance were performed with the reactor at power.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 10 and GDC 26.

2.

10 CFR 50.46.

3.

UFSAR, Section 15.4.3.

4.

UFSAR, Section 15.4.

5.

UFSAR, Section 4.3.1.5.

6.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

7.

UFSAR, Section 15.0.