ML17300B238

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Proposed Tech Spec Surveillance Requirement 4.1.3.1.2, Exempting Control Element Assemblies 27 & 41
ML17300B238
Person / Time
Site: Palo Verde Arizona Public Service icon.png
Issue date: 12/29/1989
From:
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
Shared Package
ML17300B237 List:
References
NUDOCS 9001080013
Download: ML17300B238 (10)


Text

ONTROLLED BY USER

'REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION Continued)

ACTION:

(Continued) b)

The SHUTDOWN MARGIN requirement of Specification 3.1.1.2 is determined at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Otherwise, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

d.

With one full-length CEA inoperable due to causes other than addressed by ACTION a.,

above, but within its above specified align-ment requirements, operation in MODES 1 and 2 may continue pursuant to the requirements of Specification
3. 1.3.6.

With one part-length CEA inoperable and inserted in the core, operation may continue provided the alignment of the inoperable part length CEA is maintained within 6.6 inches (indicated position) of all other part-length CEAs in its group and the CEA is maintained pursuant to the r equirements of Specification 3.1.3. 7.

SURVEILLANCE RE UIREMENTS

4. 1.3.1.1 The position of each full-length and part-length CEA shall be deter-mined to be within 6.6 inches (indicated position) of all other CEAs in its group at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> except during time intervals when one CEAC is inoperable or when both CEACs are inoperable, then verify the individual CEA positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
4. 1.3. 1.2 Each full-length CEA not fully inserted and each part-length CEA which is inserted in the core shall be determined to be OPERABLE by movement of at least 5 inches in any one direction at least once per 31 days<

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Page 1 of 5 H-Study of the Risk Impact ofa 90 Day Suspension ofSurveillance Testing for Two Unit 2 CEAs 1.0

SUMMARY

The study shows that even under a series of conservative modeling assumptions the incre-mental core damage risk incurred by suspending testing oftwo CEAs for a 90 day period is much less than 1% ofthe base case PRA core damage frequency forPVNGS Unit 2. This conclusion is arrived at by analyzing the combined probability ofa reactor trip and subse-quent RCS overcooling along with the failure ofboth ofthe parked CEAs to insert on de-mand. This was determined to be the only situation under which failure ofthese two CEAs to insert could potentially lead to fuel damage.

2.0 INTRODUCTION

Two CEAs in PVNGS Unit 2 have been withdrawn fullyfrom the core and "parked" due to significant indications of ground shorts in their coil assemblies. While in this position, the CEAs willnot be moved for normal operations, but willstill drop into the core upon a scram signal. In order to avoid the possibility of one ofthese faulty CEAs slipping during the exercise, exemption from the monthly surveillance testing ofthese two rods during the next 90 day period is desired.

Since these CEAs willnot be tested during this period there is an increased probability that one or both ofthem would failto fullyinsert given a scram signal. In such an event the pri-mary safety concern is the possiblity that the reactor willnot be taken subcritical or that subsequent RCS overcooling willpermit a return to criticalityin the vicinityof the stuck rods. Itwas the intent ofthis study to investigate the additional risk ofinducing fuel element damage that would be incurred by operating the unit without performing the monthly ST on the parked CEAs for a 90 day interval.

3.0 METHODOLOGY8c ASSUMI'TIONS Investigation by the, Nuclear Fuel Management group has indicated that the reactor willbe taken subcritical eve@ ifthe two CEAs of concern failto insert as long as other failures don't occur which would result in major RCS overcooling. For this reason the the only ac-cident conditions addressed by this study were those involvingsignificant RCS overcooling

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Page 2 of 5 in conjunction with failure of the two CEAs to insert.

The scenarios identified as having the potential forsignificantly overcooling the RCS were:

A)Main Steam Line Break or spurious opening ofmultiple Main Steam Safeties (MSSVs), Atmospheric Dump Valves (ADVs), or Turbine Bypass Valves (TBVs) while at power.

B) Any hansient leading to reactor trip and subsequent failure to reclose of the ADVs, MSSVs, or TBVs that normally unction to provide steam gener-ator steam relief.

In order to determine the probability ofincurring fuel damage due to either Case Aor Case B above, the incremental likelihoodthat the two parked CEAs failto insert is needed. There is nothing related to the grounding fault problems with the CEAs that would incline them to have a different probability of failing to insert than any other CEAs. Only the period of time that elapses between tests of the rods may cause the failure to insert rate exhibited by these CEAs to differfrom that of the others. The true failure mechanism that causes a CEA to stick most likelyhas both a time-related and a demand-related component to it. That is, wearout ofcertain parts due to rod movement demands probably contributes to a rod stick-ing, as does certain time-dependent mechanisms such as corrosion and aging effects. Thus, itis possible that the suspension oftesting for these two CEAs forthis modest interval may have no impact on (or even decrease) their failure to insert probability. For this study itwill be conservatively assumed that their failure rate is entirely time-dependent, such that the probability of a rod failing to insert on demand is a linear function of the time since it was last tested.

An estimate of the hourly stuck rod failure rate forPVNGS may be made by dividing the number of occurences ofa rod sticking by the total CEA commercial operating hours for all 3 units. There has been one occurence of a rod sticking in the approximately 3.9 x 10 CEAcommercial operating hours to 12/20/89 (Based on the 89 fulland partial length CEAs in each unit). Table 1 below shows that the derived stuck rod hourly failure rate forPVNGS falls very close to that given in INPO Report 87-022 for C-E plants. Itshould be noted that the latter rate is based on 2.4 x 107 CEA hours in all C-E plants between 1981 and 1985.

TABLE 1. HOURLYCEA FAIL-TO-INSERTRATES PVNGS (3 Units, 1 event)

I INPO Report 87-022 2.6xl0 7 /h 2.1x10 7/h For comparison purposes the demand failure rate for the CEAs was also calculated based on the single stuck rod event and the summed "totalizer" counts for all CEAs in all three

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Page 3 of 5 units. The total number ofCEA "demands" was found to be 4.6x10 to 12/20/89.

Table 2 shows the PVNGS estimated rate in comparison to the value used in the System 80 PRA conducted by C-E.

TABLE2. DEMAM)CEA FAIL-TO-INSERTRATES PVNGS (3 Units, 1 event)

C-E System 80 PRA 2.2x10

/demand 3.0x10

/demand Here the large difference is probably due to the fact that the C-E data is based only on total "scram" events, whereas the PVNGS value considers all rod movements as demands.

Again, only the hourly rates were used in determining stuck rod probability for this study.

The scenarious ofconcern involve both parked CEAs failingto insert. The jointprobability of this event cannot be simply calculated as the product ofeach rods failure probability since itwillbe dominated by common cause failure ofthe two CEAs to insert. The C-E Sys-tem 80 PRA gives a conservative beta factor for common cause oftwo CEAs to insert of 0.2. The value is derived Qom NRC documents concerning ATWS (notably SECY-83-293).

Applying this beta factor to the PVNGS single stuck rod hourly failure rate gives a failure rate for two CEAs failing to insert of5.2x10

/h.

Case A: Main steam line break or multiple spurious open ofsteam relief valves.

Either a severe main steam line break (MSLB) or the spurious opening and failure to reclose ofmore than one ADV,MSSV, or TBVwilltrip the reactor and subsequently overcool the RCS to the extent that a localized return to power is of concern. Although it is likelythat such a power transient would be self limitingdue to the coolant voiding in the fuel assembly channels, this cannot be assured without detailed neutronic/thermal-hydraulic analysis. As such, it is conservatively assumed for this analysis that the Case A scenario in conjunction withthe two CEAs stuck leads to some degree offuel damage.

The yearly frequency for MSLB or multiple failures of steam relief valves was obtained from the C-E System 80 PRA (Pg 6-11). The documents medi-an value was converted to a mean of2.7x10 ~/y. This was conservative in that itincludes stuck open TBVs even though such an overcooling transient could be readily terminated by closing the MSIVs. The incremental risk incurred in Case A due to',suspending testing of the parked CEAs for 90 days may now be estimated ~:

Incr. FueIDam = Prob ofMSLB in 60 days *Mean prob both CEAs stick

[2.7xl0 /8760 h

  • 60 d *24h/d]
  • f.5
  • 5.2x10 /h
  • 60 d
  • 24h/d]

= 1.6x10 ~

0 PageSofS IncrFuel Damage = Prob ofplant trip/60 d *Mean prob both CEAs stick

  • Prob 2 or more MSSVs stick open

= 1trip * [.5 *5.2x10 /h*60d *24h/d] *[4 MSSVs *2SGs *Sx10+]

= 2.4x10 7 Again, 60 days represents the additional exposure time of the untested CEAs over and above the normal 30 day interval between tests.

It should be noted that inboth cases the common cause failure exposure time was assumed to be increased by the suspension of testing of the parked CEAs. This is another conserva-tism since the mechanism(s) that lead to common cause failure to insert ofCEAs are the same forALLthe CEAs. Thus, in reality even the parked CEAs are tested for common cause failure whenever any CEA is tested."

4.0 RESULTS The increased risk offuel damage due to suspending testing oftwo Unit 2 parked CEAs for 90 days is estimated as the sum ofthe contributions from Cases A Ec B described in Section 3.0:

Incremental prob of f'uel damage = 1.6x10

+ 2.4xl0

= 2.6x10 7 This is much less than 1% of the total core damage frequency of approximately 1.0x10 which is anticipated when the PVNGS PRA is completed.

5.0 CONCLUSION

S The study showed that the incremental coze damage risk incurred by suspending testing of two CEAs for a 90 day period is not a significant concern. Even under a series ofconserva-tive modeling assumptions the risk of even localized fuel damage is much less than 1% of the base case PRA core damage frequency for PVNGS Unit 2.

Iftesting ofthe two parked CEAs is suspended while at power even the small incremental risk incurred could be further reduced by appropriate briefing ofoperators on the stuck rod/

RCS overcooiing scenario. Maximum boration should be initiated as soon as possible in the event the rods don't insert followinga scram.

- 4 Page4of5 Note that 60 days represents the additional exposure time of the untested CEAs over and above the normal 30 day interval between tests. Thus this cal-culation willyield the increase in risk above that normally incurred.

Case B: Any transient leads to reactor trip and ADVs, MSSVs, or TBVs that normally provide steam relieffailto reclose leading to RCS overcooling Failure to reclose of any single one of these steam reliefvalves represents a

much less severe overcooling transient than a MSLB and was assumed here

'to be insufficient to cause a return to power. In addition the induced overcool-ing would progress slowly and provide ample time forthe operators to either isolate the open valve (in the case ofthe TBVs) or to initiate boration via the HPSI or charging pumps. At least two steam relief valves were assumed to have to fail to reclose in order to induce severe enough RCS overcooling to cause a return to power.

The yearly frequency ofall reactor trips as employed in the PVNGS PRA is 4/yr. This reduces to.66 in the 60 day extension interval that the parked CEAs are exposed to. Itwas conservatively assumed for this analysis that one plant trip occurs in this time period.

Industry failure data indicates that the MSSVs have the highest likelihood of failing to reclose after opening so they were selected to represent the stuck steam relief valves for this analysis. There are ten MSSVs per steam genera-tor and it was assumed that four of the valves on each generator liftsubse-quent to plant trip. This was again a conservative assumption based on the relief capacity of each MSSV. The PVNGS PRA failure rate for an MSSV sticking open'is 8.0x10 /demand. This is the value determined by combining data from several sources as derived in the MONJU PRA. The probability of two or more MSSVs sticking open willbe dominated by common cause fac-tors. NUREG/CR-4780 (Pg 3-58) provides an estimate ofa generic beta fac-tor forPWR safety/relief valves of.07. This value was conservatively increased to.1 forthis analysis due to the uncertainty in applying such gener-ic data to a speciftc plant. The resnltinggrobabtiity for two or more MSSVs failing to reclose after opening is 8x10 /demand. The C-E System 80 PRA gives a frequency of6.0x10 /yformultiple MSSVs sticking open. If4 trips per year are assumed and the MSSVs are assumed to be demanded subse-quent to one ofthem, the demand rate derived above is equivalent to a fre-quency of about 6Ax10 /y. (4 MSSVs *2'SGs

  • 8xl0 ). This appears conservative relative to the C-E value.

The incremental risk ofincurring fuel damage in Case B due to suspending testing of the parked CEAs may now be estimated as: