ML18030A093

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Forwards Request for Amend to ITS Approving Use During Susquehanna Ses Unit 2 Eighth Refueling & Insp Outage Scheduled for 970315
ML18030A093
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 02/11/1997
From: Byram R
PENNSYLVANIA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18026A472 List:
References
PLA-4565, NUDOCS 9702190308
Download: ML18030A093 (7)


Text

CATEGORY j.

'i 6" '...0 'REGDLRT INFORMATION DISTRIBDTIQ1ISTEM (RIDE)

ACCESST'.>Nf NOR 9702190308 'OC.DATE: 97/02/11 NOTARIZED: YES DOCKET FACiIL,';!ii387 Susquehanna Steam Electric Station, Unit 1, Pennsylva I'5000387 DV; 388 Susquehanna Steam, Electric Station, Unit 2, Pennsylva 05000388 AUTH. NAME AUTHOR AFFIL'IATION BYRAMiR.G. Pennsylvania Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

. Forwards .request for amend to ITS approving use during Susquehanna SES Unit 2 eighth refueling 6 insp outage scheduled for 970315.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES: 05000387 RECIPIENT COPIES RECIPIENT COPIES 0

ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-2 LA 1 1 PD1-2 PD 1 1 POSLUSNY,C 1 1 INTERNAL: ACRS 1 1 FILE CENTER 01 1 1 NRR/DE/ECGB/A 1 1 RR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL.: NOAC 1 1 NRC PDR 1 D

NOTES: 1 1 0 U

E NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE'ONTACT THE DOCUMENT CONTROL DESKi ROOM OWFN 5D-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL. 14

0 t C Pennsylvania Power 8 Light Company Two North Ninth Street ~ Allentown, PA 18101-1179 ~ 610/774-5151 Robert G. Byram Senior Vice President-Nnclenr 610/774-7502 Fax: 610/774-5019 FEB 11 1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P 1-137 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENTNO. 20S TO LICENSE NO. NPF-14 AND PROPOSED AMENDMENT NO. 167 TO LICENSE NO. NPF-22: SINGLE CONTROL ROD WITHDRAWALIN HOT SHUTDOWN AND COLD SHUTDOWN Docket Nos. 50-3S7 and 50-3SS Pennsylvania Power & Light Company requests that two sections of the Improved Technical Specifications (ITS) which were submitted to the NRC in a letter (PLA-4488) dated August 1, 1996, be approved for use during Susquehanna SES Unit 2's Eight Refueling and Inspection Outage which is scheduled to begin on March 15, 1997. The two ITS sections are LCO 3.10.3, "Single Control Rod Withdrawal - Hot Shutdown" and LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown". This proposed amendment formats these ITS sections for use in the current Technical Specifications for both Susquehanna SES units and does not change the technical content of the ITS sections which have been submitted for public comment.

The current Technical Specifications do not allow the withdrawal of control rods in OPERATIONAL CONDITIONS 3 and 4 except for the purpose. of coupling and uncoupling of control rods. The performance of withdrawing a single control rod for other purposes is desirable to improve control rod drive system performance, reduce the chance of reactivity control device manipulation errors and support outage objectives. The proposed change adds two Special Test Exceptions to the Technical Specifications. These Special Test Exceptions allow single control rod withdrawal in OPERATIONAL',CONDITIONS 3 and 4 to perform control rod testing, scram timing and coupling integrity checks. The proposed changes have been submitted to the NRC as part of the Improved Technical Specifications (ITS) as Specifications 3.10.3 and 3.10.4.

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FILE R41-2 PLA-4565 Document Control Desk This change requests that Specifications 3.10.3 and 3.10.4 which were submitted as part of the ITS be approved for use in the current Technical Specifications for Susquehanna SES. The Specifications submitted as part of ITS have been re-formatted to fit the format of current Technical Specifications. If the ITS submittal referenced specific LCOs and the current Technical Specifications do not contain the same references, the LCO, action and surveillance requirements of the ITS submittal are included in their entirety and not referenced in the proposed changes.

For example, the ITS Sections reference LCO 3.9.2, "Refuel Position One-Rod-Out Interlock".

However, in the current Technical Specifications an exact cross reference does not exist.

Therefore, in the proposed change the entire LCO, Actions and Surveillance Requirements for ITS Section 3.9.2 are included in the requested changes to the current Technical Specifications.

The following ITS Sections are also included in their entirety in these proposed changes: 3.9.4, "Control Rod Position Indication," and 3.9.5, "Control Rod Operability - Refueling".

Refer to the attached marked up Technical Specifications.

The safety analysis submitted with the ITS submittal is not changed due to the formatting of the section for use with the current Technical Specifications for Susquehanna SES. The following is a summary of the analysis performed for the ITS submittal ~

With the reactor mode switch in the Refuel position, the analyses for control rod withdrawal during refueling are applicable and provided the assumptions of these analyses are satisfied in OPERATIONAL CONDITIONS 3 and 4, these analyses will bound the consequences of an accident. Explicit safety analysis in FSAR Section 15.4.1, "Rod Withdrawal Error - Low Power," demonstrates that the functioning of the refueling interlocks and adequate Shutdown Margin (SDM) will preclude unacceptable reactivity excursions.

Refueling interlocks restrict the movement of control rods to reinforce operational procedures that prevent the reactor from becoming critical. These interlocks prevent the withdrawal of more than one control rod. Under these conditions, since only one control rod can be withdrawn, the core will always be shut down even with the highest worth control rod withdrawn if adequate SDM exists.

FILE R41-2 PLA-4565 Document Control Desk The control rod scram function provides backup protection in the event normal refueling procedures and the refueling interlocks fail to prevent inadvertent criticalities during refueling.

Alternate backup protection can be obtained by ensuring that a five by five array of control rods, centered on the withdrawn control rod, are inserted and incapable of withdrawal (i.e., electrically or hydraulically disarmed). This alternate backup protection is required when removing a Control Rod Drive (CRD) because this removal renders the withdrawn control rod incapable of being scrammed.

7 D I. Involve a significant increase in tlute probability or consequences of an accident previously evaluated.

With the reactor mode switch in the Refuel position, the analyses for control rod withdrawal during refueling are applicable and, provided the assumptions of these analyses are satisfied in OPERATIONAL CONDITIONS 3 and 4, these analyses will bound the consequences of an accident. Explicit safety analysis in FSAR Section 15.4.1.1, "Rod Withdrawal Error-Low Power", demonstrates that the functioning of the refueling interlocks and adequate Shutdown Margin (SDM) will preclude unacceptable reactivity excursions. The proposal to format the ITS section submittals for use in the current Technical Specifications is administrative in nature. The formatting does not change any of the technical requirements that were evaluated in the ITS submittal. Therefore, neither the formatting of the ITS sections for use in the current Technical Specifications nor the technical requirements as submitted in the ITS involve a significant increase in the probability or consequences of an accident previously evaluated.

II. Create tire possibility of a <<eiv or different kind of accirlent from any accident previously evaluated.

With the reactor mode switch in the Refuel position, the analyses for control rod withdrawal during refueling are applicable and, provided the assumptions of these analyses are satisfied in OPERATIONAL CONDITIONS 3 and 4, these analyses will bound the consequences of an accident. Explicit safety analysis in FSAR Section 15.4.1.1, "Rod Withdrawal Error-Low Power", demonstrates that the functioning of the refueling interlocks and adequate Shutdown Margin (SDM) will preclude unacceptable reactivity excursions. The proposal to format the ITS section submittals for use in the current Technical Specifications is administrative in nature. The formatting does not change any of the technical requirements that were evaluated in the ITS submittal. Therefore, neither the formatting of the ITS sections for use in the current Technical Specifications nor the technical requirements as submitted in the ITS create the possibility of a new or different kind of accident from any accident previously evaluated.

4 FILE R41-2 PLA-4565 Document Control Desk III.Involve a significant redaction in a snargin ofsnfety.

For the reasons discussed in items I and II above, as well as the Safety Assessment, neither the formatting of the ITS sections for use in the current Technical Specifications nor the technical requirements as submitted in the ITS involve a significant reduction in a margin of safety.

The proposed Technical Specification changes are administrative in nature, and will therefore have no impact on the environment.

Pennsylvania Power & Light Company requests that this change be approved by March 14, 1997, in order to support the Eight Refueling and Inspection Outage on Unit 2 and continued operation of Unit 1.

Ifyou have any questions, please contact Mr. C. T. Coddington at (610) 774-7531.

Very truly yours, Attachment copy: NRC Region I Mr. K. Jenison, NRC Sr. Resident Inspector Mr. C. Poslusny, Jr. NRC Sr. Project Manager Mr. W. P. Dornsife, PA DEP

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