ML17158C118
| ML17158C118 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/23/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17158C117 | List: |
| References | |
| NUDOCS 9705010340 | |
| Download: ML17158C118 (10) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.165TO FACILITY OPERATING LICENSE NO.
NPF 14 AMENDMENT NO. 137TO FACILITY OPERATING LICENSE NO. NPF-22 PENNSYLVANIA POWER
& LIGHT COMPANY ALLEGHENY ELECTRIC COOPERATIVE INC.
SUS UEHANNA STEAM ELECTRIC STATION UNITS 1
AND 2 DOCKET NOS. 50-387 AND 50-388
- 1. 0 INTRODUCTION By letter dated 'August 1,
1996, the Pennsylvania Power and Light Company (the licensee or PP&L) submitted a request for changes to the Susquehanna Steam Electric Station, Units 1
and 2, Technical Specifications (TSs).
The requested changes would convert the current TSs for the two units to a set of Improved Technical Specifications (ITS) based on NUREG-1433, Revision 1,
"Standard Technical Specifications for General Electric Plants, BWR/4,0 dated April 1995.
A February.11, 1997, application requested that Sections 3.10.3 and 3. 10.4 of the ITS package be approved ahead of the entire ITS conversion and in a modified current TS format to enable PP&L to take advantage of these ITS limiting conditions for operation (LCOs) during the upcoming Unit 2 refueling outage beginning in mid March.
By letter dated April 7,
- 1997, PP&L amended the February 11, 1997 application to correct typographical errors in two of the footnotes in the proposed TS.
The August 1, 1996 application was noticed in a Notice of Consideration of Issuance of Amendments dated October 30, 1996, published in the Federal Re<eister on November 5, 1996 (61 FR 56972).
The February 11, 1997 application was noticed in a separate Notice of Consideration of Issuance of Amendments dated February 28,
- 1997, published in the Federal Receister on Narch 5, 1997 (62 FR 10090).
The April 7, 1997 supplement was within the 'scope of these two notices.
2.0 EVALUATION In its submittal dated August 1, 1996, the licensee included Sections
- 3. 10.3 and 3. 10.4 in accordance with NUREG-1433.
Sections
- 3. 10.3 and 3. 10.4 are intended to permit the withdrawal of a single control rod for testing while in hot shutdown and cold shutdown, respectively.
In MODE 3 or MODE 4, the reactor mode switch is maintained in the shutdown position, and all control rods are inserted and blocked from withdrawal.
Circumstances do arise when in these
- modes, that present the need to withdraw a single control rod for tests (such as friction tests, scram time tests, and coupling integrity tests).
These tests are executed by placing the reactor mode switch into the refuel position.
The proposed IT~ sections provide the appropriate additional controls to allow a single control rod to be withdrawn in MODES 3 or 4.
97050l0340 970423 PDR ADQCK 05000387 P
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2.1 ITS LCO 3.10.3 This discussion addresses the aspects of the proposed changes to the TS section that are considered more restrictive than the SSES current TS (CTS).
CTS Table 1.2, Note "***,"provides an allowance for placing the Reactor Mode Switch in Refuel and withdrawal of a single control rod while in MODE 3 as long as the One-Rod-Out Interlock is OPERABLE.
ITS 3. 10.3, Single Control Rod Withdrawal-Hot Shutdown, as proposed, formally establishes this allowance and adds restrictions consistent with CTS 3;9. 10. 1, which already allows placing the Reactor Mode Switch in Refuel and withdrawing a single control rod while in MODE 4.
The additional requirements that ITS 3. 10.3 establishes for withdrawing a single control rod while in MODE 3 include the option of having scram insertion capability for the withdrawn control rod or having all other rods in the five by five array inserted and disarmed.
Scram insertion capability is implemented by requiring control rod OPERABILITY and Reactor Protection System (RPS) requirements associated with the Scram Discharge Volume level.
(Note that other RPS functions required by ITS 3. 10.3.d. 1 are already required in MODE'3 in SSES CTS Table 3.3. 1-1.)
In lieu of establishing automatic scram capability for the withdrawn control rod, ITS
- 3. 10.3, Item d.2, allows establishing conditions that preclude the possibility of a local reactivity excursion.
This option is consistent with administrative controls required in SSES CTS 3.9. 10. I.c and d for similar operations in MODE 5.
Finally, ITS 3. 10.3.b requires that control rod position indication must be.OPERABLE to support the One-Rod-Out Interlock and all other control rods must be fully inserted.
Along with these restrictions, ACTIONS are included to identify the compensatory measures and Completion Times for noncompliance with these Special'perations requirements.
Since no ACTION is included in the CTS (associated with this footnote allowing withdrawal of a single control in MODE 3), the change is more restrictive because additional requirements are established.
Also, Surveillances are added to provide compliance with this Special Operations requirement.
The staff finds this change to be conservative in nature.
4 This discussion addresses the aspects of the proposed changes to the TS section that are considered'less restrictive than the SSES CTS.
CTS Table 1.2, Note "***"for MODE 3, allows the Reactor Mode Switch to be placed in Refuel and
- a. control rod withdrawn in MODE 3 if the One-Rod-Out Interlock is OPERABLE.
This allowance permits recoupling a control rod.
ITS 3. 10.3 and
- 3. 10.4 incorporate this allowance and extend it to include any control rod withdrawalnot just to "recouple" a control rod.
Reactivity excursions are prevented by a combination of the shutdown margin (SDH) and the One-Rod-Out Interlock and because the SDM will maintain the core subcritical even with the single most reactive rod fully withdrawn.
The allowance provided by ITS
- 3. 10.3 is covered by a safety analysis that justifies the combination of the One-Rod-Out Interlock and SDM to prevent inadvertent criticality in MODE 5.
2.1 ITS LCO 3.10.4 This discussion addresses, the aspects of the section that are considered administrative in nature as compared to the SSES CTS.
- Table 1.2 Note, "***,"governing single control rod removal in both NODE 4 and NODE 5, are split into ITS 3. 10.4, Single Control Rod Withdrawal Cold-
- Shutdown, and ITS 3. 10.5, Single Control Rod Drive (CRD) Removal Refueling.
Therefore, the ITS presents different requirements for single rod withdrawal/drive removal in NODE 4 and NODE 5.
In MODE 4 (ITS 3. 10.4) the Special Operations exception must allow for the withdrawal/removal of the control rod, as well as allow for CRD removal.
Therefore ITS LCO Items b. 1 and b.2 are both provided to utilize the OPERABLE One-Rod-Out Interlock to withdraw the control rod and then initiate the rod block during the drive removal.
Note that the SSES CTS allowance to withdraw the control rod in NODE 4 is specifically provided in Table 1.2 of the Definitions Section (footnote
><***>>5/ ~
CTS 3.9.10.1, Item a, and CTS 4.9.10.1.a require the OPERABILITY of the Reactor Node Switch during a.single control rod or CRD removal while in MODE 4.
ITS 3. 10.4, Single Control Rod Withdrawal - Cold Shutdown, provides the options of having ITS 3.9.2, Refuel Position One-Rod-Out Interlock (Option
- 3. 10.4.b.l) or a control rod withdrawal block inserted (Option 3. 10.4.b.2).
ITS 3. 10.4 identifies that the specific function of the Reactor Node Switch must be required OPERABLE instead of a general OPERABILITY requirement for the Reactor Node Switch and references to other requirements.
Specifically, the ITS requires OPERABILITY of the One-Rod-Out Interlock (if the Reactor Mode Switch is in Refuel) or an in-place control rod block (if the Reactor Node Switch is in Shutdown).
With this revised presentation that specifies only the safety function required, no mention of the Reactor Node Sw'itch position is necessary.
ITS 3. 10.4.b. 1 also includes a specific requir'ement to ensure the "Full-In" position indication OPERABILITY per ITS 3.9.4 to support the One-Rod-Out Interlock when it is credited.
These
- changes, consistent with the standard technical specification (STS),
are administrative because the ITS still requires OPERABILITY of the Reactor Node Switch with ITS 3.10.4 more specifically stating the CTS requirements.
CTS 3.9.10.1.b requiring source range monitor (SRH)
OPERABILITY in NODE 4 during single rod withdrawal/drive removal and the associated surveillance requirement (SR) in CTS 4.9. 10. l.b are'ross references to the normal NODE 4 requirements for SRH OPERABILITY.
ITS 3.10.4 does not modify the SRM NODE 4 requirements; therefore, CTS 3.9.2 (ITS 3.3. 1.2) must be met during Special Operation, ITS 3. 10.4, but the requirement does not have to be repeated in ITS
- 3. 10.4.
This is an administrative change because there is no change to the CTS requirements.
CTS 3.9. 10. I.c. 1 and 3.9. 10. l.c.2 provide clarification to the normal SDN requirements.
These CTS requirements specify that the control rod being withdrawn may be assumed the highest worth control rod assumed fully withdrawn in the SDM calculations and need not be assumed stuck (which would require that SDN consider that another rod is also withdrawn).
ITS also specifies
- that the control rod withdrawn under ITS 3.10.4 be considered the "highest worth control rod" that is assumed fully withdrawn in the definition of Shutdown Margin.
Since the single highest worth rod need only be considered once in the SDH calculations, this rod is not required to be considered a
stuck rod'and.'the additional wording is unnecessary.
This is an administrative change because there is no change to the CTS requirements.
CTS 3.9. 10.1.d and CTS 4.9.10.1.d permit a control rod adjacent to the control rod withdrawn under Special Operation ITS 3. 10.4 to be withdrawn if the four fuel assemblies surrounding the control rod are removed.
ITS 3. 10.4 deletes this option.
ITS 3. 10.4 is applicable in MODE 4 when it is unlikely that fuel would be missing from a control rod cell; therefore, this option is not included in ITS LCO 3. 10.4.
ITS 3. 10.4 ACTIONS are preceded by the Note "Separate Condition entry is allowed for each requirement of the LCO."
This note is not included in the CTS.
This note provides more explicit instructions for proper application of the ACTIONS for ITS compliance.
In conjunction with ITS 1.3, "Completion Times," this Note provides direction consistent with the ITS ACTIONS.
This Note ensures that each ITS 3. 10.4 requirement is treated independently to allow the specified period of time to verify compliance with the requirement
- and, when necessary, take the appropriate ACTION.
CTS 3.9. 10. 1, governing single control rod or CRD removal, requires the removal activity suspended and ACTIONS initiated to satisfy requirements if a control rod or CRD is removed and CTS 3.9. 10. 1 requirements are not met.
- 3. 10.4 provides additional detail for these ACTIONS depending on whether the affected control rod is insertable.
This detai,l is consistent with the CTS requirement to "initiate action to satisfy the above requirements."
Specifically, if the withdrawn control rod is insertable (ITS 3. 10.4, ACTION A), ITS 3. 10.4 Required Action A.2. 1 requires action initiated immediately to fully insert all insertable control rods.
Required Action A.2.2 requires placing the Reactor Mode Switch to the Shutdown position to prevent withdrawal of any control rod.
These ACTIONS will result in exiting the Applicability of the Special Operation ITS 3. 10.4 and return the Reactor Mode Switch to its required position for normal MODE 4 operation.
If the withdrawn control rod is not insertable, Required Action B.2. 1 requires action initiated immediately to fully insert all control rods.
This Required Action will essentially result in exiting the Applicability of the Special Operations requirement.
CTS 3.9. 10. 1 and CTS 4.9. 10.1 state that requirements for removing control rods and drives apply "until all control rods and control rod drive mechanisms are reinstalled and all control rods are inserted in the core."
A statement that requirements are applicable until the conditions under which they are required to apply no longer exist is true for all requirements and is not retained in ITS 3. 10.4.
Deleting this statement is an administrative change consistent with the STS.
ITS 3.10.4, Required Action A.l, is added to acknowledge that ITS 3.10.4 requires compliance with other requirements, and that if ITS 3. 10.4 is not met because one of the requirements by ITS 3.10.4 is not met, then entry into ACTIONS for that requirement satisfies ITS 3. 10.4.
Note 1 to Required Action A. 1 provides the additional clarification that if a Required Action for a requirement is not met, inserting all control rods results in exiting ITS 3.10.4 because the Reactor Mode Switch is returned to the Shutdown position.
This is an administrative change because it is consistent with interpretation of the CTS requirement.
CTS 3.9. 10. l.a requires the Reactor Mode Switch OPERABLE and locked in Shutdown or in the Refuel position.
ITS 3. 10.4 requires the Mode Switch in the Refuel position, but does not require it to be locked.
ITS 3.9.2 defines the requirements for locking the Reactor Mode Switch.
This discussion addresses the aspects of the section that are considered less restrictive than the CTS.
CTS 3.9. 10. 1 ACTIONS requires."completion of the moveme'nt of the component to a safe conservative position" prior to suspending removal of the control rod or CRD mechanism.
ITS 3. 10.4 requires the removal of the control rod or CRD
'echanism suspended but does not specify the movement completed to a safe conservative position.
The stipulation "completion of the movement of the component to a safe conservative posi'tion" does not impact the requirement to suspend the activity.
Therefore, this requirement is defined and controlled in the ITS Bases, which require change control in accordance with ITS 5.5. 10, "Bases Control Program."
This provides an effective level of regulatory control and provides for an appropriate change control process.
Safety is unaffected by the change because there is no change in the requirement to suspend the activity.
, CTS 3.9.10. I.d and 4.9. 10.1.d require a control rod to be disarmed and specify how"electrically or hydraulically."
ITS 3. 10.4 requires the control rods
- disarmed, but does not specify how they are disarmed.
The method of disarming the control rods does not impact the requirement to disarm the control rods.
Therefore, these details 'are defined and controlled in the ITS Bases, which require change control in accordance with ITS 5.5. 10, "Bases Control Program."
This provides an effective level of regulatory control and provides for an
'ppropriate change control process.
Safety is unaffected by the change because there is no change in the requirement to disarm the control rods.
CTS 4.9.10.
1 requires that verifications associated with single control rod removal be performed "within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the start of removal" and at least every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter.
ITS eliminates the requirement that verifications be performed "within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the start of removal."
This will allow the verifications to be performed up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the start of withdrawal or removal of the control rod or drive.
This change is acceptable because the requirement that the requirements of ITS 3. 10.4 be maintained whenever control rods are withdrawn or remo!ed is unchanged.
Elimination of the requirement to perform this verification within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to control rod removal is not
significant because the normal periodic Surveillance Frequency is established to provide adequate assurance that requirements are being met.
If the Surveillance has been performed within the normal specified interval, reliance on the results is allowed since ITS SR 3.0.4 requires only that a Surveillance be performed within the required Frequency prior to'ntering the applicable
'ODE or condition.
The 24-hour Surveillance Frequency provides adequate assurance that the LCO requirements are satisfied.
If any Surveillance has not been performed within this interval, control rod withdrawal and CRD removal may not be performed.
This ensures the requirements are adequately checked prior to and during control rod withdrawal operations.
ITS 3. 10.4, governing control rod withdrawal in MODE 4, allows a new option in place of the requirements for SDM and disarming all control rods in a five-by-'ive array if a control rod is withdrawn (but the CRD is not removed) in MODE 4.
The alternative requirements are that ITS 3.9.5, Control Rod OPERABILITY - Refueling, be met and the MODE 5 Reactor Protection System Functions OPERABLE.
Therefore, the new alternative to establishing conditions that ensure a reactivity excursion will not occur is to ensure that if a reactivity excursion does occur, the RPS will initiate a scram and the withdrawn control rod will insert.
- However, adopting this alternative requires that, in addition to the MODE 5 RPS Functions already required by CTS Table 3.3. 1-1, ITS 3. 10.4 ensures the Scram Discharge Volume level functions are OPERABLE so that control rods will insert if a scram signal occurs.
CTS Table 3.3. 1-1, Functions S.a and S.b, which govern Scram Discharge Volume level functions, although required OPERABLE in MODE 5 with any 'control rod withdrawn, are not required if the control rod is withdrawn in accordance with CTS 3.9. 10. 1 (or CTS 3.9. 10.2),
because the RPS OPERABILITY option for controlling reactivity excursions during single control rod withdrawal is not permitted in the CTS.
New Surveillances are added to perform the applicable SRs (ITS SR 3. 10.4. 1) if RPS Functions and control rod OPERABILITY requirements are chosen, and to verify every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that a control rod withdrawal block is inserted (ITS SR
- 3. 10.4.4) if the block is the chosen requirement.
CTS Table 1.2; Note "***"for MODE 4, allows the Reactor Mode Switch to be placed in Refuel and a control rod withdrawn in MODE 4 if the One-Rod-Out Interlock is OPERABLE.
This allowance permits recoupling a control-rod.
ITS 3. 10.4 formally incorporates this allowance and extends it to include any control rod withdrawal not just to "recouple" a control rod.
Reactivity excursions are prevented by a combination of the SDM and the One-Rod-Out-Interlock because the SDM will maintain the core subcritical even with the single most reactive rod fully withdrawn.
Therefore, the allowance provided by ITS 3. 10.4 is covered by safety analyses that justify the combination of the One-Rod-Out Interlock and SDM to prevent inadvertent criticality in MODE 5.
Based on the above, the staff has determined that Sections
- 3. 10.3 and 3. 10.4 described in the August 1, 1996, submittal for SSES are consistent in form and content with these sections of NUREG-1433 and are acceptable.
The staff has
( ~
also reviewed the interim version of these sections, which have been formatted
. to correspond to the CTS, requested in the February 11, 1997, application.
The version in the February ll, 1997, application also includes the appropriate cross references to the CTS sections for consistency and utility by operations staff.
This amendment action hereby approves the in'terim version of ITS Sections 3.10.3 and 3.10.4 for inclusion in the CTS in the Special Test Exception Sections
- 3. 10.7 and 3. 10.8 along with applicable Bases changes and the addition of a reference to Table 1.2.
Sections
- 3. 10.3 and
- 3. 0 STATE CONSULTATION In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
Pursuant to 10 CFR 51.21, 51.32, and 51.35, an environmental assessment and finding of no significant impact have been prepared and published in the Federal
~Re ister on April 11, 1997 (62 FR 17886).
Accordingly, based upon the environmental assessment, the staff has determined that the issuance of the amendment will not,have a significant effect on the quality of the human environment.
- 5. 0 CONCLUSION The Commission has concluded, 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 oper'ation in the proposed
- manner, (2) such activities will be conducted in compliance with the Commission s regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
C. Poslusny Date:
Apri1 23, 1997
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