ML20054G988

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Discusses Tech Spec Amend 51 Re Rod Position Indication Sys, Per 820616 Discussion.Approval of Interim Change to Tech Spec 3.1.3.3 Requested by 820621
ML20054G988
Person / Time
Site: Beaver Valley
Issue date: 06/16/1982
From: Carey J
DUQUESNE LIGHT CO.
To: Varga S
Office of Nuclear Reactor Regulation
Shared Package
ML20054G989 List:
References
TAC-48510, NUDOCS 8206220471
Download: ML20054G988 (2)


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Telephone (412) 4564000 Nuclear Division P.O. Box 4 Shippingport, PA 150774004 June 16, 1982 Director of Nucicar Reactor Regulation United States Nuclear Regulatory Commission Attn: Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Washington, DC 20555 heference: Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Technical Specification Amendment 51-Rod Position Indication System Gentlemen: ,

This letter is to document discussions between K. D. Grada of Duquesne Light and Messrs. Tam, Ahmad and Beard of your staf f on June 16, 1982.

Duquesne Light Company had requested in previous letters on this amendment, that the applicability of Technical Specifications 3.1.3.3 regarding monitoring of the analog to demand position accuracy within 112 steps at temperatures below 547F, be deferred until operating temp-eratures are attained. This was requested to account for the downscale shift in the analog position at lower coolant temperatures and would

[,rovide for hot calibrations of this system.

It is our understanding that this exclusion is acceptable on an interim basis, pending the outcome of a meeting between Duquesne Light and your staff that is tentatively scheduled for July 13, 1982. We had also requested that the statement provided on page 1-20c of our June 11, 1982 letter be issued as part of this amendment. It was our intent to avoid reporting of routine computer, or, rod deviation monitor alarm outages, providing that the accelerated four-hour checks on verifying analog to demand indication were implemented. It is our position that the absence of this statement will result in numerous incident reports, consume numerous staf f hours for preparation and review and be counter productive since agreement between analog channels and demand position is surveilled by the operation during rod motion. We understand that this issue will be discussed during the forthcoming meeting.

We have stated that there is no safety issue associated with deviations between the analog rod position indicators or analog to demand accuracy at lower system temperatures, or, indeed at low power due the large thermal margins with respect to DNB. Mr. J . T. Beard asked if the accuracy of the shutdown nargin calculation is af fected if rod position was not I206220471 820616 DR ADOCK 05000334 PDR

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- Docket No. 50-334, License No. DPR-66 Technical Specification Amendment 51-Rod Position Indication System June 17, 1982 Page 2 accurately known during this period and questioned if the potential for an inadvertent criticality could be increased. We stated that the shutdown margin calculation in Modes 3, 4_and 5 is based on boron concentration and rod position has no relevance in calculating the cold shutdown margin. Since dilution of the reactor coolant system for the critical rod height'can only-be performed at operating temperatures, when rod position is well esta-blished and the shutdown banks are withdrawn, the potential for-an inadvertant criticality is not increased.

-The shutdown margin calculation performed in Modes 1 and 2 does utilize control rod position, and it is only during this period that the

!12 step accuracy requirement should be imposed in consideration of peaking tactors, rod insertion limits and available shutdown margin.

Our current schedule requires that this interim change to specifi-cation 3.1.3.3 be approved by June 21, 1982. If you have any questions on this issue, please contact my office immediately.

J. J. Carey Vice President, Nuclear cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555