ML20112K025

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Proposed Tech Specs,Clarifying Surveillance Requirements for Rod Position Indication in Modes 3,4 & 5,to Allow Closing of Reactor Trip Sys Breakers
ML20112K025
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 04/02/1985
From:
DUKE POWER CO.
To:
Shared Package
ML20112K021 List:
References
TAC-57322, TAC-57323, NUDOCS 8504090304
Download: ML20112K025 (3)


Text

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REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEM-SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.3.3 One rod position indicatcr (excluding demand position indication) shall be OPERABLE and capable of determining the control rod position within i 12 steps for each shutdown or control rod not fully. inserted.

APPLICABILITY:

MODES 3*#, 4*# and 5*#.

ACTION:

With less than the above required position indicator (s) OPERABLE, immediately open the Reactor Trip System breakers.

I SURVEILLANCE REQUIREMENTS 4.1.3.3 Each of the above required rod position indicator (s) shall be determined to be OPERABLE by performance of an ANALOG CHANNEL OPERATIONAL TEST at least orce per 18 months.

The Reactor Trip System Breakers can be closed in order to perform this surveillance.

"With the Reactor Trip System breakers in the closed position, the Control Rod Drive System capable of rod withdrawal.

  1. See Special Test Exception 3.10.5.

McGUIRE - UNITS 1 and 2 3/4 1-18 hDR 369 p

PDR-

p Attichment II Justification and Safety Analysis The proposed change of the Technical Specifications is concerned with the Surveillance Requirements associated with Specification.3/4.1.3.3, Rod Position Indication System.

The proposed change to Surveillance Requirement 4.1.3.3 will add the statement, "The Reactor Trip System Breakers can be closed in order to perform this surveillance",

and to the applicability footnote specify that the Control Rod Drive System is capable of rod motion. The Analog Channel Operational Test is specified in the Specification ~ for this surveillance and is used in conjunction with rod motion to verify operability of the Rod Position Indicators. This operation requires one worker to be in the vessel head area for approximately tairty minutes.

If a rod position indicator has been declared inoperable, the required Action is to immediately open the Reactor Trip System Breakers.

In this situation it becomes impossible to move the rods.

To. perform the surveillance without moving the rods requires six workers approximately three days in the vessel head area to make all required connections and perform the test. This proposed change would allow the Reactor Trip System Breakers to be closed to verify Rod Position Indicator operability by rod motion, which would be consistent with ALARA considerations.

The' proposal to change the footnote is to specify that the Specification doese not ap' ply if the rods are incapable of being withdrawn. This is of no safety concern as the Rod Position Indicators are not needed if the rods cannot be withdrawn and may prevent unnecessary opening the Reactor Trip System Breakers.

The proposed change would have no impact upon plant safety.

The specification is applicable in' Modes 3, 4,' and 5 (Hot Standby, Hot Shutdown, and Cold Shutdown, respectively), all of which specify a suberitical condition. The proposed change would not affect the required shutdown margin that must be ' maintained in accordance with Technical Specifications 3/4.1.1.1 and 3/4.1.1.2 (Shutdown Margin for Tavg

>200*F and Shutdown Margin for Tavg <200*F, respectively). The proposed change would only allow the Reactor Trip System Breakers to be closed to perform the required surveillance; the t.ction statement in the event of an-inoperable indicator remains the same.

The proposed change of Technical Specification 3/4.1.3.3 is a needed clarification of the Surveillance Requirements that does not involve a reduction in any margin of safety'and is consistent with ALARA considerations.

u

g :s Attachment III ANALYSIS OF SIGNIFICANT HAZARDS CONSIDERATION Pursuant to the requirements of 10CFR50.91, this analysis provides a determination that.the proposed amendment of the. Technical Specification does not involve any significant hazards consideration, as defined by 10CFR50.92.

The proposed change of Technical Specification 3/4.1.3.3 supplies a needed clarification to the surveillance Requirements. The proposed amendment is consistent with'ALARA considerations, and has no effect upon the required

- shutdown margin that must be maintained.

The proposed amendment would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or
2) Create the possibility of a new or different kind of

~

accident from any accident previously evaluated; or

'3)

Involve a'significant reductin in a~ margin of safety.

. Based upon the preceding analysis, Duke Power Company concludes that the proposed amendments do not involve a significant hazards consideration.

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