ML20128C937

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Summary of 921110 Meeting W/Util in Rockville,Md Re Two Issues Affecting Activities Performed During Refueling Outages
ML20128C937
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 01/14/1993
From: Clark R
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
NUDOCS 9302040209
Download: ML20128C937 (13)


Text

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n UNITED STATES

/ 3 i NUCLEAR REGULATORY COMMISSION o I WAsHINoToN, D C. 206M

%'.... */ January 14, 1993 Docket Nos. 50-352 and 50-353 LICENSEE: Philadelphia Electric Company FACillTY: Limerick Generating Station, Units 1 and 2

SUBJECT:

SHUTDOWN MARGIN DETERMINATION On November 10, 1992, a meeting was held at One White Flint North with representatives of the Philadelphia Electric Company (PEco) to discuss two issues affecting activities performed during the Limerick Generating Station (LGS) refueling outages. A list of attendees is enclosed (Enclosure 1). .The agenda for the meeting is presented in Enclosure 2. The slides used by the licensee are presented in Enclosure 3. The issues focus on PEco's performance of control rod withdrawal for operability testing during the reactor vessel hydrostatictestinginOPERATIONALCONDITION(OPCON)4,ColdShutdown. The first issue concerns the means by which Technical Specification (TS) Limitir,g Condition for Operation (LCO) 3.1.1, " Shutdown Margin" is satisfied. The second issue concerns the position of the Reactor Protection System (RPS) shorting links, described by Note "c" in TS Table 3.3.1-1, " Reactor Protection System Instrumentation." Section 3.1.1 of the Limerick TSs requires that "the SHUTDOWN MARGIN shall be equal to or greater than:

a. 0.38% Ak/k with the highest worth rod analytically determined., or
b. 0.28% Ak/k with the highest worth rod determined by test."

Section 4.1.1 states that "The SHUTDOWN MARGIN shall be determined to be equal to or greater than specified at any time during the fuel cycle:

a. By measurement, prior to or during the first startup after each refueling.

Table 3.3.1-1 of the Limerick TSs lists the reactor protection system instrumentation channels that must be operable. Note "c" to this Table states:

"(c) The " shorting links

  • shall be removed from the RPS circuitry prior to and during the time any control rod is withdrawn

Control rod scram time testing is normally performed during Operational hydro, following fuel loading and installation of the reactor vessel head. Control rod scram timing requires each individual control rod to be fully withdrawn 290070 m <m c, m--., , , .

9302040209 930114 PDR ADOCK 05000352 gli P PDR U.,

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. and scrammed into the reactor. During the first two refueling outages of Unit 1, during performance of the Operational hydro, single rod scram timing and control rod stroke timing were performed by taking the reactor mode switch to REFUEL, thereby activating the one-rod-out interlock. This action ensures that only one control rod can be withdrawn at a time. There are a number of other requirements that must also be met; for example, the Standby Liquid Control system must be operable and available to inject sodium pentaborate in the event of inadvertent criticality.

During the review of the Unit 2 startup test procedures prior to issuance of the fuel load license in June 1989, an NRC inspector raised the question as to whether scram time testi- *hould be conducted during the vessel hydrostatic in operational condition sp Con) 4, instead of during plant startup, since the sour a range monitors (SRM) are not in the RPS logic circuit. In addition, the inspector questioned if the requirement of TS 3.9.2 for demonstrating adequate shutdown margin (SDM) could be met through an analysis, inasmuch as TS 4.1.1 mentions that the SOM should be determined by measurement. (See Inspection Reports 50-352/89-12 and 50-3E3/89-19 and Section 5.0 of Inspection Reports 50-352/89-15 and 50-353/89-24). The issue was resolved at the time (prior to Unit 2 initial fuel load) by the licensee revising Startup Test Procedure (STP) - 5.6, " Rated Reactor Pressure Scram Testing" to remove the shorting links during the entire test period when control rods are withdrawn. This provides SRM and non-coincident Ni scrams in the case of inadvertent criticality.

PEco presented information describing its justification for maintaining the RPS shorting links installed during refueling outage evolutions at times other than when the TS explicitly requires the RPS shorting links to be removed (e.g., 15 Section 3.10.3, " Shutdown Margin Demonstrations"). Removing the RPS shorting links results in the RPS trip logic for nuclear instrumentation being -

one-out-of-one; i.e., a single non-coincident signal will result in a reactor trip. Removal of the coincident function in the RPS logic will increase the-probability of inadvertent reactor SCRAM due to RPS instrument spiking caused by random signals er workers coming in contact with under-vessel instrument cables. While not a safety issue alone, if the reactor SCRAM signal occurs while all control rods are inserted, the unmitigated pressure transient (i.e.,

the pre:sure differential between the pressurized hydraulic control units and the depressurized reactor vessel) challenges the integrity of the Control Rod -

Drive (CRD) seals and drive mechanisms. In addition, since all SCRAM occurrences must be investigated before plant operations can continue (i.e.,

in this case, refueling operations) inadvertent SCRAMS can cause an increase in the refueling outage length. Furthermore, with the RPS shorting links o -installed, multiple (i.e., redundant) nuclear instruments monitor the i reactivity in each reactor core region, thereby protecting against reactor criticality events. Accordingly, the Intermediate Range Monitors (IRMs) on l range I will cause a reactor SCRAM prior to the time the SRM rod block L

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setpoint (i.e., 100,000 cps) is achieved. Note that these events occur prior to the SCRAM that would be initiated by the SRMs (i.e., at 200,000 cps) if the shorting links are removed and furthermore, no setpoint for an SRM high neutron flux level scram is specified in the Technical Specifications. Also, no credit is taken for an SRM initiated reactor SCRAM in the accident or transient analysis in the Updated Final Safety Analysis Report.

The NRC staff advised PEco that the analytically calculated Shutdown Margin can be used to satisfy TS Limiting Condition of Operation (LCO) 3.1.1 during such evolutions as scram time testing of one control rod at a time durinq hydrostatic testing in OPCON 4, cold shutdown. The first rod to be pullsd should be the highest worth rod as determined by the analytical determination.

The shorting links do not need to be removed. The-one-rod-out interlock shall be activated to prohibit withdrawal of more than one control rod at a time.

The shutdown margin must, however, be actually determined by measurement in OPCON 2 Startup to satisfy TS Surveillance Requirement 4.1.1. No changes to the present TSs are necessary to permit stroke and scram testing of the control rods during hydrostatic testing. Original signed by Richard J. Clar , r'ojfcNanager Project Directorate I-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

Enclosures:

1. List of Attendees
2. Meeting Agenda
3. Licensee's slides cc w/ enclosures:

See next page l DISTRIBUTION 2 Docket file. LScholl NRC'& Local PDRs CDoutt PDI-2 Reading CShulten TMurley/FMiraglia HRichings  !

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SVarga VMcCree JCalvo EWenzinger, RGN-1 CMiller CAnderson, RGN-I RClark CGrimes M0'Brien FRinaldi OGC EJordan  ;

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0FFICIAL RECORD COPY /

DOCUMENT NAME: Lill-10. HTS-

setpoint (i.e., 100,000 cps) is achieved. Note that these events occur prior to the SCRAM that would be initiated by the SRMs (i.e., at 200,000 cps) if the shorting links are removed and furthermore, no setpoint for an SRM high neutron flux level scram is specified in the Technical Specifications. Also, no credit is taken for an SRM initiated reactor SCRAM in the accident or transient analysis in the Updated Final Safety Analysis Report.

The NRC staff advised PECo that the analytically calculated Shutdown Margin can be used to satisfy TS Limiting Condition of Operation (LCO) 3.1.1 during such evolutions as scram time testing of ona control rod at a time during hydrostatic testing in OPCON 4, cold shutdown. The first rod to be pulled should be the highest worth rod as determined by the analytical determination.

The shorting links do not need to be remov?d. The one-rod-out interlock shall be activated to prohibit withdrawal of more than one control rod at a time.

The shutdown margin must, however, be actually determined by measurement in OPCON 2 Startup to satisfy TS Surveillance Requirement 4.1.1. No changes to the present TSs are necessary to permit stroke and scram testing of the control rods during hydrostatic testing.

hard-thlark, Project Manager roject Directorate I-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

Enclosures:

1. List of Attendees
2. Meeting Agenda
3. Licensee's slides cc w/ enclosures:

See next page

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4

[ Philadelphia Electric Company Limerick Generating Station, Units 1 & 2 cc:

J. W. Durham, Sr., Esquire Mr. William P. Dornsife, Director Sr. V.P. & General Counsel Bureau of Radiation Protection Philadelahia Electric Company PA Dept. of Environmental Resources ,

2301 Marcet Street P. O. Box 2063 Philadelphia, Pennsylvania 19101 Harrisburg, Pennsylvania 17120 Mr. Rod Krich 52A-5 Mr. James A. Muntz Philadelphia Electric Company Superintendent-Technical 955 Chesterbrook Boulevard Limerick Generating Station Wayne, Pennsylvania 19007-5691 P. 0. Box A Sanatoga, Pennsylvania 19464 Mr. David R. Helwig, Vice President Limerick Generating Station Mr. Gil J. Madsen Post Office Box A Regulatory Engineer Sanatoga, Pennsylvania 19464 Limerick Generating Station P. O. Box A Hr. John Doering Sanatoga, Pennsylvania 19464 Plant Manager Limerick Generating Station Library P.O. Box A US Nuclear Regulatory Commission Sanatoga, Pennsylvania 19464 Region 1 475 Allendale Road Regional Administrator King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission Region I Mr. George A. Hunger 475 Allendale Road Project Manager King of Prussia, PA 19406 Limarick Ge.1erating Station P. O. Box A Mr. Thomas Kenny Sanatoga, Pennsylvania 19464 Senior Resident inspector .

US Nuclear Regulatory Commission Mr.' Larry Hopkins P. O. Box 596 Superintendent-0perations ,

Pottstown, Pennsylvania 19464 Limerick Generating Station P. O. Box A Mr. Di:hard W. Dubiel Sanatoga, Pennsylvania 19464 Superihtendent - Services Limerick Generating Station Mr. George J. Beck P.O. Box A Manage. Licensing, MC 52A-5 Sanatoga, Pennsylvania 19464 Philadelphia Electric Company Nuclear Group Headquarters Correspondence-Cnntrol Desk P.O. Box No. 195 Wayne, Pennsylvania 19087-0195 l

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ENCLOSURE 1 L11L Of ATIENDEES MEETING WlE _ff,(g ON $HUIDOWN MARGH tiOVEMBER 10. J112 tLE DEEM 11AH0!1 R. Clark 11RC/NRA L. 5:ho11 NRC/ Resident inspector C. Doutt NRC/NRR C. Schuit(n NRC/NRR H. Richings NRC/NRR 0 tief f PECo R. Krich PECo C. Bornand PEco J. Podlesney PEco H. Eyre PECo i

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DJCLOSURE 2 Meeting Agenda llovember 10, 1992 Philadelphia Electric Company Limerick Generating Station and office of Nueionr Reactor and Regulations TOPIC: Shutdown Margin McAr9rJauent and Control of Rod Withdrawal Daring a Refueling Outage PURPOSE: ro present interpretation of Toch Specs To reach common understanding To identify necessary action DISCUSSIO!1:

I Introduction of Dackground Rod Krich, Licensing II 3equence of Outage Activitics John Podlesney, Limerick Reactor Engineering III SDM Demonstration by Analysis Christine Dornand, for Tech Spec 3.1.1 Fuel Management IV Summary of Tech Spec David Meff, Limerick Interpretation Licensing V Questions and Discussion VI Conclusion and Summary of Action Items

DELOSURE 3

.I LIMERICK GENERATING STATION l

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! REFUELING SEQUENCES

. . , , . , , . _ . . , . . . , . . . . . . . . - . ~ . - . . . . , . , , . . - . . . , , - - _ . . . , . - . - . , . _ _ . . _ . . . _ - . . - . , . _ . . . ~ , , . . , , . . . . . , - . . . - . , .

LIMERICK ~ REFUELING PRESENT OFF LOADlRELOAD

> OFF LOAD CORE Msds' 5

> PERFORM HCU/CRDICRB MAINTENANCE

> DYNAMIC VENT ALL MAINTENANCE LOCATIONS

> VERIFY ALL CONTROL RODS ARE FULLY INSERTED

> RELOAD CORE

> VERIFY CORE LOADING

> NOTE: THE NEXT FOUR STEPS HAVE BEEN REQUIRED SINCE LGS 2 INITIAL CORE LOADING.

> 1. REMOVE SHORTING LINKS

> 2. SCRAM CONTROL RODS FOR

  • 3. PERFORM

> 4. INSTALL SHORTING LINKS

> START OPS HYDRO

> STROKE / SCRAM CONTROL RODS DURING OPS HYDRO .

> PERFORM SHUTDOWN MARGIN MEASUREMENT DURING START UP dpcon 2

. = - _ - .-

LIMERICK REFUELING
PROPOSED OFF LOAD / RELOAD .- -

l .

> OFF LOAD CORE

> PERFORM HCU/CRD/CRB MAINTENANCE _

4

> DYNAMIC VENT ALL MAINTENANCE LOCATIONS

> VERIFY ALL CONTROL RODS ARE FULLY INSERTED

> RELOAD CORE

> VERIFY CORE LOADING

> START OPS HYDRO

> STROKE / SCRAM CONTROL RODS DURING OPS HYDRO

> DECLARE CONTROL RODS OPERABLE

> PERFORM SHUTDOWN MARGIN MEASUREMENT DURING START UP I

l

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LIMERICK REFUELING PROPOSED FUEL SHUFFLE _

> SHUFFLE FUEL TO MAINTENANCE CONFIGURATION

> WITHDRAW CONTROL RODS REQUIRING MAINTENANCE

> PERFORM HCU/CRD/CRB MAINTENANCE

> DYNAMIC VENT ALL MAINTENANCE LOCATIONS

> VERIFY ALL CONTROL RODS ARE FULLY INSERTED

> SHUFFLE FUEL TO FINAL LOADING

> VERIFY CORE LOADING

> START OPS HYDRO

> STROKEISCRAM CONTROL RODS DURING OPS HYDRO

> DECLARE CONTROL RODS OPERABLE

> PERFORM SHUTDOWN MARGIN MEASUREMENT DURING START UP

0 i 1

Analysis satisfies requirement of LCO 3.1.1 to permit control rod operability testing ,

during OPCON 4. '

BASES:

9 Use NRC-approved methods. 1 i

9 Apply NRC-approved design mhrgin. /gs---

&,,,,, arp,/s at yJ . S- e.<< n as, sa<1ng & {

/.rg 4

9 Analysis is complete prior to core loading. 1 l

4 9 Tests orlor to startup do NOT quantify CSDM.

%,,,J; 4,,y s / a a is & a sc. w a/

9 Single rod withdrawalis more conservative than multiple rod withdrawal.

O Licens'ed operators monitor nuclear during all control rod withdrawal, monitoring  :

power changes.

9 Consi,*ent with Improved Tech Specs.

p,u/,,u ca<, .udr.sf sco .

l RPS SHORTING LINKS NOT REQUIRED TO BE REMOVED BASES:

  1. Tech Spec Table 1.2 does not require removal.

m Mde Y

  1. IRMs on Range 1 will SCRAM prior to SRM 100,000 cps.

4 Multiple instruments monitoring each region.

9 No credit given for SRM SCRAM in accident / transient analyses.

9 No RPS setpoint for SRM hllevel SCRAM.

  1. inadvertent SCRAM more likely.

Detrimental to equipment increased outage time, for cause lovestigation.

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