ML20134J624

Rev 0 to Tmr 96-0003, Safety Evaluation

ML20134J624
Person / Time
Site:	Fermi
Issue date:	03/13/1996
From:	Klemptner A DETROIT EDISON CO.
To:
Shared Package
ML20134J609	List: ML20134J606 ML20134J624
References
TMR-96-0003, TMR-96-0003-R00, TMR-96-3, TMR-96-3-R, NUDOCS 9611150309
Download: ML20134J624 (12)

Text

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, , SAFETY EVALUATI@N i i , SE 96- 0022 Rev 0

Pase 1 of 7 l

} PART1: DESCRIPTIONOFCHANGE(P>nparer) l l A) Document Identification B) Revision if Approved C) PIS Number

! TMR 96 0003 0 Cl102D0162 (CRD 34 31)

D) Description of Change:

Temporary removal ofinput signal to the " CONTROL ROD OVERTRAVEL " alarm wmdow 3D105 from Control Rod Drive 34-31 Position Indscation Probe. (coatmuod on page 2)

E) List of affected/ reviewed UFSAR/TS sections: 4.5.2.2, Figures 4.5-11 through -14,7.7.1.1.5.2, Table 7.7-1, Figure 7.7 1, sh.1,15.4.9/ 3.1.3.2,3.1.3.6,3.1.3.7.

F) List any associ nted license eksene requests (LCRs): N/A PART2: 54FETYEVALUATION(P>qmrwr)

A) WiB the proposed change:

Yes No Q li5 1. Increase the probability or the consequences of an accident previously evaluated in the UFSAR?

O E 2. Increase the probability or the consequences of a malfunction of equipment important to safety previously evaluated in the UFSAR?

O E 3. Create the possibility of an accident of a diferent type than any previously evaluated in the UFSAR?

Q li5 4. Create the possibility of equipment malfunction of a diferent type than any previously evaluated in the UFSAR?

O E 5. Reduce the margin of safety as defined in the bases for any technical specification?  !

l Provide the basis for each answer individually on a Continuation Sheet.

B) Unreviewed safety question? Answer "Yes" if any of the above boxes are checked "Yes."

Q Yes E No C) Prepared by A. Klemptner Date 03/12/96 PART3: REVIEWAND APPROVAL (Rvwr/AppvrA0$RO)

Date $~ l3 "f &>

B) Approved by a _ ih*V c e- Date % 'I '"> O

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Mbb o.teJ/a/s NOTE: If an unreviewed safety question is involved, and/or the proposed activity leads to the need for a change in the Operating License, Technical Specifications, or Environmental Protection Plan, consult Nuclear Licensina.

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SAFETY EVALUATION CONTINUATION SHEET 1

SE 96 0022 Rev. 0 l

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The purpose of this Safety Evaluaten is to perform a 10 CFR50.59 review of a temporary moddication TMR

%0003, Rev. D. This TMR will tsunporanly defeat the rod overtravel alarm funcuan for Control Rod Drive (CRD) 34-31 Position Indication Probe (PIP).

PROBLEMDESCRIM10N:

DER 96-0155 was initiated on February 14,1996 in response to an mp-*ed actuation of alarm annunciator wmdow 3D105 " CONTROL ROD OVERTRAVEL". The position ofevery control rod in the core is continuously sensed by an assec4ated position in& cation probe (PIP) and displayed in the full cost and 4-rod group indicators at Control Rocm Panel HilP603. The position in& cation actuation device is a magnetically coupled reed switch A column of these switches is mounted on the probe structure of the CRD unit. As the control drive moves, the magnet located ir. the base of the CRD drive piston causes individual reed switches to close. Reed switches are numbered sequentially from 00 (fully inserted rod) to 48 (fully withdrawn rod). If the control rod in the full out position (position 48) becomes uncoupled from its drive mechanism, the CRD will drift or may withdraw to activate the overtravel alarm "Ihe overtravel of any CRD is indicated by a common annunciator alarm Window 3D105. The generation of an alarm signal is an in&catson of a potential fault in the PIP circuitry, if none of the rods are selected or moving. Any ground on the input pins of the grouping temunal

._ cards that assemt,le the CRD overtravel signals from the PIPS would cause this indication TMR 96-0003 was prepared to isolate a faulty rod overtravel input signal from CRD 34 31 PIP into the common alarm circuit.

EXISTINGDESIGN Rod Position Information System (RPIS) provides control rod position informaten to visual displays used by the reactor operators to monitor the rod movements Each CRD is equipped with a position indicator probe fitted with glass-enclosed rood switches. The switches are nW by a ring magnet located at a bottom of the drive piston (see UFSAR, Figure 4.5 14). One switch is located at each position correspondmg to an index tube groove, thus allowing in& cation at each latching point. An additional switch is located at each midpoint between latching points to indicate the interme& ate positions during drive motions and is used to indicate rod driA. A drifting rod is indicated by an alarm and red light in the main control room.

One additional switch (an overtravel switch) is located at a position below the normal full out position (Position 48). If the rod drive piston moves to overtravel position, an alarm is sounded in the main control room. The overtravel alarm is one of the several ways to venfy that the drive-to-rod coupling is intact because the drive cannot be physically withdrawn to the overtravel posstion when the control rod is coupled to its drive. Coupling stegrity can be checked by attempting to withdraw the drive to the overtravel position.

RPIS provides two kinds of visual displays at the Control Room Panel (COP) HI1P603: full-core and 4-rod group display.

The full core display includes a group of status indicators for each rod in the core. The followmg information for

' each control rod is presented in the display: Rod fully inserted (green), Rod fully withdrawn (red), Rod ,

identification (coordinate position, white), Accumulator trouble (amber), Rod scram (blue), and Rod drift (red).

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i l "Ihe 4-rod group display shows the position of any one w.L4-selected rod plus the positions of several

a4acent rods. Position is shown as a two<hgit docunal number valued from 00 (rod full-in) and 48 (rod full-l out). A white light indicates which of the four rods in the group is selected for movemmit l

l The position signals of selected control rods, together with a rod Manhnemfinn gggggl, are provided as inputs to

the on-line process computer and the Rod Worth Mininnaer (RWM). The w,...,.c can, on demand, provide a

! full core printout of control rod positions i PROPOSED CHANGE:

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TMR 96 0003, Rev. O will temporarily defeat the rod overtravel alarm function for CRD 34-31. This work I will be performed in the Relay Room Panel HI1P615 by disconnecting Pin "X"in the multi conductor receptacle JIX125 of plug-connected cable 233271 OK. This L #.ry modi 6 cation will remove one input to i the overtravel alarm circuit to facilitate the performance of surveillance procedures in the presence of a faulty i sustamed overtravel alarm signal from CRD 34-31.

l The overtravel indication is used to determme control rod's coupling status during periodic surveillances and while monitoring rod position information during normal plant operation Periodic surveillances test the coupling of the rods by attempting to withdraw the rod drive beyond the 48 and

! Full-out position in compliance with the Techmcal Specifications (TS) 4.1.3.6 requirements The current j procedure verifies that control rod settled back to position 48 and annuamatinn wmdow 3D105, CONTROL

ROD OVERTRAVEL is clear.

The behavior of the 48, Full out, and overtravel indications may all be used to reach and venfy a conclusion j regarding the coupling integrity of the control rods, since they are sensed by the switches of the same type and j by a similar electrome process An uncoupled rod would be indicated by (a) activation of the overtravel alarm,

(b) loss (blankmg) of the position 48 display, and (c) de energiation of Full-out light, and (d) activation of the j rod driA alarm Consequently, an alternate method to determine rod coupling integrity during surveillance l testing and normal plant operation has been speci6ed by General Electne (GE) via a letter GE-NE.Cl 100256-j 13 Rev.1. The attemate method takes credit for the operability of the control rod 48 position and Full-out rod

! position indicatson to confirm that CRD 34-31 is coupled.

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l Review of CRDs corrective maintenance activities, and DER data base information did not identify any uncoupling events in the past associated speci6cally with CRD 34 31. Reactor Naamng's " PIP Malfunctions Tracking Log" does not show any malfunctions associated with CRD 34-31 aAer it was replaced i in Forced Outage 95-02 (Work Request 0002952306) other than an overtravel alarm .

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Page 4 of 7 i r I To support conclusions of this Safety Evaluation, the following ad-i-terrative measures should

} incorporated into the TMR %0003 implernention plan

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1. Second licensed operator or other technically quali6ed person is present at the CO.* Hi lP603 to observe i rod position indication whenever a planned CRD 34-31 coupling integrity check is to be performed, and i 2. CRD 34-31 is declared INOPERABLE if a malf4 of control rod 48 position indication, Full out i

t rod position indicaten, or Rod DriA alarm is danetadai' ponWea 44. d8k, 8//

DESIGNE4SE CRITEMA:

GW +1h.,

j The RPIS is part of the Reactor Manual Control Systan (RMCS). The RPIS electronically processes data i

from the CRD assembly position and indicator probe, and distributes the processed data to operators displays, j

annunciators, the process computer, and the RWM. The RPIS is part of a power genersten system and is not classified as safety related. The design basis for the RPIS is to provide the means for reactor operators to deternune control rod position, and provide an indicaten of the CRD driA and overtravel.

4 The RPlS complies with the requirements of the 10CFR50, Appendix A, General Design Criteria (GDC) 13

(Instrumentation & Control), where the instrumentation is required to be provided to monitor and contro!

variables that can affect the fission process within reactor core over their anticipated ranges for normal i

operaten, and for anticipated operational occur aces DESIGNE45E CNM8L4 MET; The RPIS provides the means to determme the OPERABILITY of an individual control rod based on a combination of factors, prunarily, scram insertion times, the control rod coupling integrity, and the ability to

detemune the control rod position. Control rod position may be determmed by the use of operable position indicators, or by moving control rods to a position with an operable indscator. Coupling verification is

performed to ensure the control rod is connected to the CRD M*Msm and will perform its intended function

, when necessary. The overtravel position feature provides a positive check on the coupling integrity, since only j an uncoupled rod can reach the overtravel position. The overtravel position feature will not be impacted by i

TMR 96-0003, since indicators other than overtravel alarm are still available to the operator, i.e.

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(a) los

(blankmg) of the position 48 display, (b) de<nergization of full out light, and

(c) activation of rod driR alarm, for determmation of CRD 34-31 coupling integrity.

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SAFETY EVALUATION CONTINUATION SHEET i SE 96-0022 Rev 0 Page 5 of 7 1

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l UNREVIE WED RAFETY OUESTIONDETERMINA TION 1

1. WiB the proposed change increase the pd ":V or the consequences of an accident previou J

evaluated in the UFSAR?

I No. Accidents are de6ned as hy* M evente that effect one or more of radioactive matenal barners and which are not cupected dunng the course ofplant operanons The most severe accident ==== tad with th l control rods is Centrol Rod Drop Acculent (CRDA) described in UFSAR, Secuan 15.4.9.

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j The CRDA resuks from a stuck control rod dropping out of the core aAer t==-% disconnected from its

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and aAer the drwe has been fully withdrawn. Tne control rod drop accident (CRDA) is the result of a pos i

event in which a high worth control rod is inserted out of-sequence into the core. Subsequently,it bes.,.i decoupled from its drive mechanism. The mechanism is 11thdrawn, but the uncoupled control roci is assumed i

I be stuck in place. At a later optimum moment the contrc. rod suddenly falls free and drops out of the core. T acuan results in she removal oflarge negative reactivity from the core, which in turn results in a localized

{ excursion.

To limit the worsk of the rod that would be dropped in a BPWS operatmg mode, the RWM is used below the low power seinoss to enforce the banked position withdrawal sequence (BPWS). The RWM...a.d is piva.

to j

i follow the BPWS. For BPWS, the effective withdrawal is in the form of(stepped) defined bank partems i

Control rod couping insagrity is required to ensure compliance with the analysis of the CRDA in the UFSAR.

The temporary less of overtravel alarm signal for CRD 34-31 will have no impact on operator's ability i

determine the couphng meegnty of CRD 34 31, because other alternate indicanons remam avadable to the l operator to deterunne the coupling integnty at all reassor levels.

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Therefore, the prehability or the consequences of an accident previously enluated in the UFSAR and the

] radioscovity reinee dose to on-site or off-site penennel will not be increased.

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1.;Will the proposed change increase the probability or the consequences of a asalfhnetion of equi

} insportant to saany previously evaluated in the UFSAR?

j 1he RPIS, tegelber with other rod control systems, is used to limit the worth of any single control rod to m the effects of the postulated CRDA or any rod withdrawal error. The RPIS displays and anon =eia*ars provi i ,

reactivity indicesion and, therefore, are important to the operators for mitiganon of the ea==ayu== of the  !

Anticapated Operauss Occurrences (AOO).

1 AOOs that have been evaluated in this casesory are control rod withdrawal enors analysed in the UFSAR,

) Secoons 15.4.1 and 15.4.2. Operator's acnons are not required , but *-4 during these events The RPIS is '

j not important for the Design Basis Accident (DBA) events analyzed in the UFSAR, Secuans 6.3,15.6 and 15.8 in j w4uch the autonunc acuans occur.

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The implementation of TMk 96 0003 will not change the information used by the operators to desemune control rod OPERABILITY, e.g. scram insertion times, the control rod couphas miegrity, and the ability to determme the l l control rod position. In fact, this TMR will allow operators to use the existing RPIS design features, i.e.

l overtravel alarm, for its inter.ded application, that is for determining all control rod coupling integrity in the l presence of a faulty CRD 3* 31 overtravel alarm input.

a j Therefore, the proposed chs. age will not increase the probability or the consequences of a malfunction of j equipment important to safe:y previously evaluated in the UFSAR.

3. Will the proposed change create the possibility of an accident of a different type than any previously j evaluated in the UFSAR?

{ No. TMR %-0003 will restore the operability of the common overtravel alarm annunciator The overtravel

! position feature provides a positive check on the rod coupling integnty, since only an uncoupled rod can reach the

ov

rtravel position. Control rod uncoupling integrity is required to ensure compliance with analysis of the CRDA j in the UFSAR, Section 15.4.9, which is the limiting design basis reactivity insertion event analyzed in the i UFSAR. The proposed TMR clears the overtravel alarm circuit for the other 184 CRDs in the presence of the 1 - faulty alarm signal from CRD 34-31. The attemate method is available to make a de6 nite deternunation

i.e.iy CRD 34-31 coupling status and take appropriate actions to operate with the uncoupled control rod within the constraints of the TS 3.1.3.1 requirements l' Therefore, the proposed change will not create the possibility of an accident of a different type than any l previously evaluated in the UFSAR.

4. Will the proposed change create the possibility of equipment malfunction of a different type than any previously evaluated in the UFSAR?

No. As stated above, the design bases of the plant in terms of the p~iel for CDRA assume a worst single operator error in the control rod withdrawal sequence la the power rarige, it is dermed as a selection and full i withdrawal of the maxunum worth control rod. This could result in the potentially high reactivity addition if the specific control rod involved is uncoupled, stuck fully inserted, and, subsequently, falls to full out position.

The implementation of TMR 96-0003 will not impact the operator's ability to make a definite deternunation for each rod that it is actually coupled. Moreover, the use of a second operator enhances continuous monitoring of the CRD 34 31 position indication. This operational admmistrative diversity ensures compliance with safe operation procedures and TS's requirements Therefore, the proposed change will not create the possibility of equipment malfunction of a different type than any previously evaluated in the UFSAR DTO TPMMLS DSN: MLS07004 Rev.0 Pl/l File:1703.22 Date: 082595 Recip:

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SAFETY EVAu. ATION CONTINUATION SHEET

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. 5. Will the proposed change reduce the smargin of safety as de6aed in the bases for any technical speci6 cation?

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No. De maram of safety ==-=W with the CRDA is denned in the bases for the TS 3/4.1.4, Control Rod Program Controls in terms ofpeak fuel enthalpy Damage to the fuel Aom the CRDA depends on the amount i of energy generated vnthin the fuel rods as a result of the rod drop. The speci6c energy desgn limit is 280 j cal /sm in the event of CRDA. Surveillance requirements ofcontrol rod coupling integrity WW in the TS j 4.1.3.6 ensure comphance with the analysis of a CRDA.

! The Bases for the TS 3/4.1.3 stipulate that a rod is considered to be uncoupled ifit reaches the overtravel j position. His feature provides the positive means for h...Eg that a rod is properly coupled. De

implementation of TMR % 0003 will not change the overtravel position feature, in fact, TMR 96 0003 will i restore the operability of the common CRD overtravel alarm annunciator wmdow 3D105.nis design feature is i described in the UFSAR, Section 7.7.1.1.5.2, Operator Informatson CRD 34-31 coupling integrity will be temporarily determmed using the alternate method duririg surveillance testmg and normal plant operation that j has been speci6ed by General Electric (GE). His method takes credit for the operability of the control rod 48

position and Fulleut rod position indication to con 6rm that CRD 34-31 is coupled.

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! Derefore, the proposed change will not reduce the margm of safety as de6ned in the bases for any technical

! speci6 cation, UFSAR or Safety Evaluation Report (SER) =artma l

l An unreviewed safety question does not exist based on the analysis and evaluation above.

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CI*d 0918-989 EIE 3MNSn dO9rtO 96-WI-JTW

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GENuclearEnergy 4 H.96028 '

3 March 6,1996 i

To: Dan Mesams  !

, From: Martin H. Lim

Subject:

ALTERNATE DETERMINATION OF CRD OVERTRAVEL INDICATION, 4

GE-NE-Cl100256-13, Revision 1 l

Dan,

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Per your request, please find attached a final copy ofrevision 1 of a letter report, GE-NE-Cl 100256-13 as prepared by GE Nuclear Energy Principle Engineer, Vem Martin.

i IfI can provide you with any additional information, please do not hesitate to call.

Sincerely, W '

Manin H. Lim OE Site Service Manager cc: T. Dong '

W. Miller J. Thorson A. Klemptner D. Ockerman i

20*d 0918-999 CIC OBNSn dSW*tO 96 - W I - J ek

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• GE NE C1100256-13, Revision 1 Page 2 l .

! (expected) behavior of the 43 and Full Out indications. De u: coupilng test is incorporated j into the normal rod esercise surveillance which inserts a fully v &lrawn rod to 46 and then withdraws it back to 43. Proper oper'a tion of the numeric indicuk i and the Pull Out l s indication should be veriSed during this change of rod position. If the 43 and Pull Out indication ate verified to be operative, then both indications tor;tNr may be used to confirm

. ibe rod is coupled.

f l Contlauous Monitoring:

An uncoupled control rod may also be detected at other thnes wir the rod is not being

! subjected so a surveillance to determine ks coupling status. Assuming an uncoupled rod's 4

index tube would settle to the overtravel position, an uncoupled rod would be indicated by the following:

$ 1. Activation of the overtravel annuncissor l 2. Loss of(blanklog of) the position 43 display i 3. De energization of the Full Outlight

4. Activation of the sod driA alarm l If the overtravel indication is inoperative, three indications remain available to the operator. ,

j De rod drift alarm also serves to draw attention to the event as soon as it occurs much the l i same way the overtravel annunciator would, he drik alarm could occur because of conditions I other than rod uncoupling. In the event a drik alarm did occur and the coupling integrity of '

the rod became in doubt, the operative rod position indications in combination with the i j surveillance activities described above provide a means of determining the rod's coupling

status. <

As stated above, the behavior of abe 43, Full Out, and overtravel indications may all be used to reach and verify a determination regarding the coupling status of the control rod. De ability i to verify the rod's coupling status is important because of the potential severity of the contro!

rod drop event. Multiple indication failures compromise the ability to reliably verify the coupling status. Control rods wbose coupling status cannot be determined should be treated as uncoupled in accordance with the plant technical siwM.cstions.

As an example, a control rod with a malfbactioning overtravel indication verified to be coupled by the method outlined in this leser and with no history of becoming uncoupled could be treated as coupled at all reactor power levels with no additional precautions or special considerations regarding its coupling status. His is because the operative position indications provide verifled evidence of coupling, provide evidence that the malfunction is strictly an indication malfunction as opposed to an actual uncompling, and the, control rod's history give no reason to believe that an uncoupling has occurred or is likely to occer.

His letter provides a basis to continue use of a control rod with a malfunctioning overtravel indication. Because of the reduction of multiple methods to determine a rod's coupling status, the methods described in this letter of using alternets indications to determine a rod's coupling status should be applied on a case 4y-case basis. As indicated in the above example, the 90 7 ' ISIB-9BS CIE ~ ~ YNSF) d9t*WO N -N WW

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GE NE-CI100256-13. Revision 1 Page 3

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prudent action for a rod with a history of uncoupling which also has degraded indications used to identify an uncoupled condition may be to declare it inoperative even if the methods of this letter indicate it is coupled. Multiple rods with degraded position indications may require a  !

] more conservative response which, in turn, may be dependent on their mutual proximity as in cases of rod inoperability. Similarly, a single rod with multiple position indication failures j may demand a score conservative response because of the compreadsed ability to verify a rod's status. These multiple failure conditions are beyond the scope of tbla letter.

Prepared by: h [M Vernon E. Martin, Verified by:

) $Vibo, Principal Engineer Principal Engineer i

l Approved by

..* fF Robert L. Hawk,  !

Electronic Systems j

Mission Manager l

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REACTIVITY CONTROL SYSTEMS '

CONTROL ROD DRIVE COUPLING j LIMITING CONDITION FOR OPERATION  !

3.1.3.6 All control rods shall be coupled to their drive mechanisms.

j APPLICABILITY: OPERATIONAL CONDITIONS I, 2, and 5*.

l ACTION:

l a. In OPERATIOML CONDITION 1 and 2 with one control rod not coupled to

its associated drive mechanism, within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s

4 1. If permittad by the RWM, insert the control rod drive mechanism j to accomplish recoupling and verify recoupling by withdrawing j the control rod, and:

I a) Observing any indicated response of the nuclear instrumentation, and b) Demonstrating that the control rod will not go to the overtravel position.

2. If recoupling is not accomplished on the first attempt or, if not permitted by the RWM, then until permitted by the RWM, declare the control rod inoperable, insert the control rod and disam the associated directional control valves ** either:

a) Electrically, or b) Hydraulically by closing the drive water and exhaust water isolation valves.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. In OPERATIOML CONDITION 5* with a withdrawn control rod not coupled to its associated drive mechanism, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> either:

1. Insert the control rod to accomplish recoupling and verify recoupling by withdrawing the control rod and demonstrating that the control rod will not go to the overtravel position, or

2. If recoupling is not accomplished, insert the control rod and disars the associated directional control valves ** either:

a) Electrically, or b) Iqydraulically by closing the drive water and exhaust water isolation valves.

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• At least each withdrawn control rod. Not applicable to control rods r %oved per Specification 3.9.10.1 or 3.9.10.2.

• • May be rearmed intermittently, under administrative control, to permit testing associated with restoring the control rod to OPERABLE status.

FERMI - UNIT 2 3/41-11 AmendmentNo.$7,83 CO*d 0918-999 EIE DMNSn d9t*tO 96-WI-JTW

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. .RLAUIVITY CONTROL SYSTEMS '

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l l JURVEILLANCE REOUIREMENTS i

I 4.1.3.6 Each affected control rod shall be demonstrated to be coupled to its - -

drive mechanism by observing any indicated response of the nuclear instrumentation while withdrawing 'the control rod to the fully withdrawn position and then verifying that the control rod drive does not go to the j overtravel position:

l a. Prior to reactor criticality after completing CORE ALTERATIONS th'at could have affected the control rod drive coupling integrity, l b. Anytime the control rod is withdrawn to the " Full out* position in i j subsequent operation, and I

c. Following maintenance on or modification to the control rod or control rod drive system which could have affected the control rod drive coupling integrity.

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FERMI. - UNIT 2 3/4 ').-12.. >

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