ML19210E524

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Discusses NRC Review of LERs & Tech Spec Requirements Re Control RPI Sys at Westinghouse Pwrs.Requests Tech Specs Review to Ensure Requirement for Rod Maint to within +/- 12 Steps Indicated & RPI Sys Verified Accurate within 12 Steps
ML19210E524
Person / Time
Site: Farley Southern Nuclear icon.png
Issue date: 10/29/1979
From: Schwencer A
Office of Nuclear Reactor Regulation
To: Barton A
ALABAMA POWER CO.
References
NUDOCS 7912050159
Download: ML19210E524 (7)


Text

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OCTOBER 29M9 Docket No. 50-348 Mr. Alan R. Barton Senior Vice President Alabama Power Company Post Office Box 2641 Birmingham, Alabama 35291

Dear Mr. Barton:

The staff has recently completed a review of the LER.'s and Technical Specification requirements related to the Control Rod Porition Indication Systems (RPI) at Westinghouse PWRs. We have detemined that a wide varia-tion exists in the number of LERS received and the technical speciPWibtion requirements and have, therefore, decided to clarify our requirements.

At the time of development of the Standard Technical Specifications, a systematic attempt was made to clarify potentially ambiguous specifications.

One such specification was the control rod misalignment specification for Westinghouse-designed reactors. Westinghouse has performed safety analyses for control rod misalignment up to 15 inches or 24 steps (one step equals 5/8 inch). Since analysis of misalignments in excess of this amount have not been submitted, we have imposed an LC0 restricting continued operation with a misalignment in excess of 15 inches. Because the analog control rod position indication system has an uncertainty of 7.5 inches (12 steps), when an indicated deviation of 12 steps exists, the actual misalignment may be 15 inches. This is because one of the coils, spaced at 3.75 inches, may be failed without the operator knowing about it. The Standard Technical Specifications were written to eliminate any confusion about this, and allow a deviation of up to 12 indicated steps. Surveillance requirements, on the indication accuracy of 12 steps were also prepared to ensure that the 15 inch LC0 is met.

There is no difference intended in requirements issued for any Westinghouse reacto r.

Westinghouse has infomed the NRC that all of their customers have been infomed of this and that all the licensees shculd be following the same procedures regardless of the language of their Technical Specification. That is, plants with Technical Specifications written in terms of 15 inch misalign-ment should be considering the 12 step ' instrument inaccuracy when monitoring' rod position.

A related problem is that the installed analog control rod position indicating system equipment may not, in some areas, be adequate to aa'.t.t.nin the control roa misalignment specification requirement because of drift problems in the calioration curves. This is evidenced by numerous LER's concerning rod position indication accuracy.

In these cases, the uncertainty may be more than 12 steps.

1498 f49 7912050 /

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Mr. Alan R. Bar. ton Alabama Power Compani

-2 CCTOBER 29573 The present Westinghouse Standard Technical Specifications (Tindicated po W-STS) require all full length control rods to be positioned within i 12 steps of their group step counter demand position. Since numerous problems have developed in signal conditioning circuits for display indication of control rod position, the staff has detemined that the " indicated position" requirement may be fulfilled by voltage measurements obtained from the position indication mechanism (and therefore no LER need be submitted) provided a sufficient data base has been established to ensure a correlation between voltage and position.

A copy of the current, applicable W-STS Specifications (3/4.1.3.1 and 3/4.1.3.2) are attached for your infomation and consideration.

It is requested that you review your present technical specifications to ensure that the control rods are required to be maintained within i 12 steps indicated and that the rod position indication system is verified to be accurate to within 12 steps.

If your review indicates that this is not the case, you should so infom the Commission within 30 days of ycur receipt of this letter together with your plans to correct the deficiencies.

Any needed corrective actions may take several foms; such as (1) revising your tecb:ical specifications to limit control rod misalignment to no more than + 12 steps indicated position, (2) seeking relief by perfoming analyses justi7ying (with penalties if needed) greater misalignments, or (3) proposing alternate or supplemental monitoring specifications to demonstrate compliance with the i 12 step indicated alienment requirement.

If you have any questions on this matter, please contact us.

Sincerel,

(/ W 4

A. Schwencer, Chief Operating Reactors Branch #1 Division of Operating Reactors

Enclosure:

W-STS Specifications 3/4.1.3.1 and 3/4.1.3.2 cc: w/ enclosure See next page 1498'150

Mr. Alan R. Barton OCTOBER 25 373 Alabama Power Company ec: Ruble A. Thomas, Vice President Southern Services, Inc.

Post Office Box 2625 Birmingham, Alabama 35202 George F. Trowbridge, Esquire Shaw, Pittman, Petts and Trowbridge 1800 M Street, N.W.

Washir.gton, D. C.

20036 John Bingham, Esquire Balch, Bingham, Baker, Hawthorne, Williams and Ward 600 North 18th Street Birmingham, Alabama 35202 Edward H. Kefler, Esquire Keiler and Buckley 9047 Jefferson Highway River Ridge, Louisiana 70123

- George S. Houston Memorial Library 212 W. Burdeshaw Street Dothan, Alabama 36303 e

1498 i51

REACTIVITY CONTROL SYSTEMS 3/4.1.3 MOVABLE C0NTROL ASSEMBLIES GRCUP HEIGHT LIMITING CONDITION FOR OPERATION 3.'l. 3.1 All full length (shutdown and control) rods, and all part length rods which are inserted in' the core, shall be OPERABLE and positioned within 212 steps (indicated position) of.their group step counter demand position.

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 knowa to be untrippable, determine that the SHUTDOWN MARGIN require-ment of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With more than one full or part length rod inoperable or misaligned from the group step counter demand position by more than 12 steps (indicated position), be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c.

With one full or part length rod inoperable due to causes other than addressed by ACTION a, above, or misaligned from its group step counter demand height by more than 12 steps (indicated position),

POWER OPERATION may continue provided that within one hour either:

1.

The rod is restored'to OPERABLE status within the above alignment requirements, or 2.

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)

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.

b)

The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.

"See Special Test Exceptions 3.10.2 and 3.10.3.

1498 152 W-STS 3/4 1-14 OCT I 193

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR' OPERATION (Continued) c)

A power distribution map is obtajned from the movable incore detectors and F (Z) and F are verified to be within their limits wikhin 72 hobgrs.

d)

[ither 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 hcJrs the high neutron flux trip setpoint is reduced to less than or equal to 85% of RATED THERMAL POWER, or

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The remainder of the rods in the group with the inoperable e

rod are alianed to within 12 steps of the inoperable rod within one hour while maintaining the rod sequence and insertion limits of Figures (3.1-1) anc (3.1-2); the THERMAL POWER level shall be restricted pursuant to Speci-fication (3.1.3.6) during subsequer.t operation.

SURVEILLANCE REOUIREMENTS 4.1.3.1.1 The position of each full and part length rod snall be determined to be within the group demand limit by verifying the individual rod positions 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 the Rod Position Deviation Monitor is inoperable, then verify the group 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 rod not fully inserted and each part length rod which is inserted in the core shall be determ'ned to be OPERABLE by move.nent of at least 10 steps in any one direction at least once per 31 days.

W (2 )

$ $5 i

W-STS 3/4 1-15 MAR 15 G77

TABLE 3.1-1 ACCIDENT ANALYSES REQUIRING REEVALUATION IN THE EVENT OF AN INOPERABLE FULL OR PART LENGTH ROD Roa Cluster Control Assembly Insertion Characteristics hod Cluster Control Assembly Misalignment Loss Of Reactor Coolant From Small Ruptured Pipes Or From Cracks In large Pipes Which Actuates The Emergency Core Cooling Systcm Single Rod Cluster Control Assembly Withdrawal At Full Power Major Reactor Coolant System Pipe Rut tures (Loss Of Coolant Accident)

Major Secondary System Pipe Rupt"re Rupture of a Control Rod Drive Mechanism Housing (Rod Cluster Control Assembly Ejection) 1498 154 1N W-STS 3/4 1-16 OCT 1 1976

REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS-OPERATING MMITINGCONDITIONFOROPERATION 3.1.3.2 The shutdown, control and part length control rod position indication system and the demand position indication system shall be OPERABLE and capable of determining the control rod positions within 12 steps.

APPLICABILITY:

MODES 1 and 2.

ACTION:

a.

With 'a maximum of one rod position indicator per bank inoperable either:

1.

Determine the position of the non-indicatir-} rod (s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and immediately 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 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

b.

With a maximum of one demand positier, indicator per bank inoperable either:

1.

Verify that all rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the b.1nk are within a maximum of 12 steps of each other *t least or.ce per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or 2.

Reduce THE 'iAL POWER to less than 50% of RATED TPERMAL POWER

, ithin 8 h: irs.

w SURVEILLANCE RE0VIREMENTS

'4.1.3.2 Each rod position indicator shall be determined to be OPERABLE by

. verifying that the demand position indication system and the rod position indication system agree within 12 steps 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 the Rod Position Deviation Monitor is-inoperable, then compare the demand position indication system and the rod position indica' tion system at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

1498 155 JUL 151979 W-STS 3/4 1-17

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