ML20151Y246

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Proposed Improved Tss,Resolving Items Identified by Util During Review
ML20151Y246
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 09/15/1998
From:
DUKE POWER CO.
To:
Shared Package
ML20151Y237 List:
References
NUDOCS 9809180165
Download: ML20151Y246 (8)


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3_r ENCLOSURE 2

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MCGUIRE NUCLEAR STATION CHANGES TO ITS SUBMITTAL t

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CHANGES TO MCGUIRE ITS SUBMITTAL 1.

Special Test Exceptions CTS 3.10.5 for Position Indication System - Shutdown was incorrectly shown in the CTS markup for ITS 3.1.8 as being deleted (DOC A26). This LCO provides an exception during testing for the rod position indication system during

- shutdown. The rod position system LCO, CTS 3.1.3.3, was previously relocated to the Selected Licensee Commitments Manual (UFSAR Chapter 16). Discussion of Change R7 is revised to indicate that the associated test exception, CTS 3.10.5, is also relocated to the Selected Licensee Commitments Manual.

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3pEcIGtcovr!m fSPECIALTESTEXLtPIIUN3 v

3/4.10.!f POSITION INDICATION SYSTE SHUT j

LIMITINGCONDITIONFOROPERATIOl d

3.10.5 The limitations of pecification 3.1.3.3 may be suspended ring the performance of individual full-length shutdown and control rod dr time measurements provided:

a.

Only one s tdown or control bank is withdrawn fro the fully inserted sition at a time, and b.

The ro position indicator is OPERABLE during e withdrawal of the rods APPLICABILI : MODES 3, 4, and 5 during performance f rod drop time measureme s.

E1 Lot!'

Wit the Position Indication System inoperabl or with more than one bank of ro s withdrawn, immediately open the Reactor rip breakers.

SURVEILLANCE REOUIREMENTS 4.10.5 The above required Rod Posi on Indication Systems shall be determi d to be OPERABLE within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> pri to the start of and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter during rod dr time measurements by verifying the De nd Position Indication System and t e Rod Position Indication Systems agree Within 12 steps wher the rods are stationary, and a.

b.

Within 24 steps d ing rod motion.

'This requi ement is not applicable during the initi i calibration of the Rod Posit' n Indication System provided: (1) K s maintained less than or equal to 0.95, and (2) only one shutdown or,,o, rol rod bank is withdrawn i c

t fully inserted position at one time.

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McGUIRE - UNIT 1 3/4 10-5 Amendment No. 166 p q 564 6

$pectG N N (SPECIAL TEST E7CEPTIONS (

^ O 3 /, Y 3/4.10.5 POSITION INDICATION SYSTEM [ SHUTDOWN

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k LIMITING CONDITION FOR OPERATION /

3.10.5 The limitations of S ecification 3.1.3.3 may be suspended during e

performance of individual f 11-length shutdown and control rod drop time measurements provided:

a.

Only.one shu own or control bank is withdrawn from the fu y inserted po tion at a time, and b.

The rod p ition indicator is OPERABLE during the wit rawal of the rods.*

APPLICABILITY:

ES 3, 4, and 5 during performance of rod rop time measurements.

LQJLO!(:

With the P ition Indication System inoperable or with more than one bank of rods with awn, inusediately open the Reactor trip b kers.

SURVE _ LANCE REOUIREMENTS

4. 0.5 The above required Rod Position Indic fon Systems shall be determined t be OPERABLE within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the art of and at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> thereafter during rod drop time me urements by verifying the Oemand Position Indication System and the Rod Pos tion Indication Syste::ts agree:

a.

Within 12 steps when the rods re stationary, and b.

Within 24 steps during rod tion.

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  • This requirement i not applicable during the initial libration of the Rod Position Indi tion System provided: (1) K is intained less than

% qual to 0.9 and (2) only one shutdown or,,o,n al rod bank is withdrawn or e c

_the fully nserted nnd +iaa =+ aa- +i=a McGUIRE - UNIT 2 3/4 10-5 Amendment No. 148 f 4-T

Discussicn cf Changas Secticn 3.1 - Reactivity C:ntrol Systems ADMINISTRATIVE CHANGES to shutdown to MODE 3 is retained as ITS 3.1.5 Action B.

The changes are considered administrative and are consistent with

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NUREG-1431.

A.22 Not used.

A.23 Specific requirements for the control bank sequence and overlap limits have been added to CTS 3.1.3.6 and 4.1.1.1.1.b on control bank insertion limits.

ITS 3.1.6 c16arly identifies that these parameters are required to be met by including specific actions and surveillance requirements.

These parameters have always been a part of the control bank insertion limit as detailed by the figure in the COLR.

No technical requirements are modified and the change is considered administrative in nature since it clarifies information already contained within the existing requirements.

The change is consistent with NUREG-1431.

A.24 CTS 3.10.3 allows exceptions tc rod alignment and insertion limits during PHYSICS TESTING in MODE 2.

With the deletion of CTS 3.1.1.1 SDM is MODE 1 and 2 (see Doc A.2), it is necessary to add appropriate requirements, actions, and surveillances to the test exception LCO. These requirements are retained as ITS LC0 3.1.8.

The change is administrative in nature, and no technical change is made. This change is consistent with NUREG-1431.

A.25 CTS 3.10.3.b requires the reactor trip setpoints of the intermediate and power range channels to be set at 25% during performance of PHYSICS TESTS. This information is redundant to the LCO 3.3.1, "RTS Instrumentation" which requires that the trip setpoints for the channels be set to 25% for the intermediate and power ranges in MODE 2.

The deletion of redundant requirements is administrative and does not represent a technical change. This change is consistent with NUREG-1431.

A.26 The exceptions to SDM provided by CTS 3.10.1, the exceptions for rod insertion and power distribution limits provided by CTS 3.10.2, cnd the exception; for red pc;ition indicction provided by

. CTS 3.10.5.are no longer needed and are deleted.

SDM will be maintained within the limits specified in the COLR during PHYSICS TESTS.

PHYSICS TESTS will be conducted in MODE 2, thus the MODE 1 1

exception provided by CTS 3.10.2 is not needed.

Red position exception i; ne lon;;cr needed in MODES 3, 4, cr 5 cnd in "005 2 McGuire Units 1 and 2 Page A - 6 Supplement 10

1 l

Discustien of Changes Section 3.1 - RIactivity Ctntrol Systems l

ADMINISTRATIVE CHANGES wie-b ' 1.0.

The ITS 3.1.8 test exceptions for PHYSICS TESTS l

j in MODE 2 provides an exception to rod alignment requirements.

F This change is consistent with NUREG-1431.

A.27 CTS 3.10.3.a allows exceptions to certaia LCOs for the performance of physics tests provided power is limited to 5 5% of Rated i

Thermal Power (RTP). This statement is redundant because the Applicability for this LCO is MODE 2 ($ 5% RTP).

ITS LC0 3.1.8 retains this same applicability during PHYSICS TESTS. With this deletion, no technical requirements are modified and the change is considered to be administrative in nature.

This change is consistent with NUREG-1431.

A.28 CTS 4.1.1.1.1.a and 4.1.1.2.a require verifying SDM when an inoperable (immovable or untrippable) control rod is disccvered.

This requirement is already contained in CTS 3.1.3.1 and is retained in ITS LC0 3.1.4 for an untrippable control rod.

These requirements already provide adequate assurance that SDM is verified and therefore, the requirements of 4.1.1.1.1.a and l

4.1.1.2.a are redundant and eliminated.

No technical requirements i

are deleted by the elimination of this redundant requirement and the change is considered administrative.

This change is consistent with NUREG-1431.

A.29 CTS 3.1.3.1 Action c.2 and c.3 contain the phrase, "The rod is declared inoperable" when a rod is not within alignment limits.

This wording does not add any clarity to the actions and is eliminated.

The format in the ITS is such that actions are only entered when the LC0 is not met, i.e. the component is inoperable.

Therefore, the additional wording is not necessary for inclusion I

within ITS 3.1.4.

No technical requirements are deleted by the elimination of this wording and the change is considered administrative.

This change is consistent with NUREG-1431.

l A.30 CTS 3.1.3.6 requires that an out of limit control bank be restored l

within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or that power be reduced to match the power limit for the exitting insertion position.

ITS 3.1.6 only requires that l

the insertion limit be restored.

The existing actions are somewhat redundant. Since there are only two ways to restore compliance (i.e., withdraw the control banks or reduce power to match control bank position), the requirement to restore limits is McGuire Units 1 and 2 Page A - 7 Supplement 10

Discussien ef Ching2s S:cticn 3.1 - Reactivity C:ntrol Systems RELOCATION is required before the shutdown margin is lost. Operations of the boration subsystem is not assumed to mitigate this event.

The CVCS System is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The CVCS System is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The CVCS System is not part of a primary success path in the mitigation of a DBA or transient. As discussed in Section 4.0 (Appendix A, page A-6) and summarized in Table 1 of WCAP-11618, the loss of the CVCS System was found to be a non-significant risk contributor to core damage frequency and offsite releases. Duke Power Company has reviewed this evaluation, conr.iders it applicable to the plant, and concurs with the assessment.

  • ince the screening criteria have not been satisfied, the Borated Water Sources - Operating LC0 and Surveillances may be relocated to the Selected Licensee Commitments Manual (UFSAR Chapter 16).

R.7 CTS 3.1.3.3 specifies requirements for rod position indication in j

MODES 3, 4, and 5.

CTS 3.10.5 provides an exception during testing for rod position indication. Control rod operability is assumed for all transients in which a reactor trip is assumed to occur. However, the 112 step alignment is not assumed when in MODES 3, 4 or 5, since no reactor power is being generated and the reactor is subcritical. The rod alignment and position indication is only necessary when the reactor is critical, to ensure proper power distribution.

1 The position indication system is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a design basis accident (DBA).

The position indication system is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient.

The position indication system is not part of a primary success path in the mitigation of a DBA or transient. As discussed in Section 4.0 (Appendix A, page A-12) and summarized in Table 1 of WCAP-11618, the loss of the position indication system was found to be a non-significant risk contributor to core damage frequency McGuire Units 1 and 2 Page R - 6 Supplement 10

n-Discussien cf Changes SIcti n 3.1 - R31ctivity C:ntral Systems b

RELOCATION and offsite releases.

Duke Power Company has reviewed this evaluation,-considers it applicable to the plant, and concurs with the assessment.

.Since the screening criteria have not been satisfied, the Position Indication System - Shutdown LC0 3.1.3.3 and its associated testing exception 3.10.5 may be relocated to the Selected Licensee Commitments Manual (UFSAR Chapter 16). Surveillance 4.1.3.3 will be retained in ITS SR 3.1.7.1 for rod position indication in MODES 1 and 2.

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l McGuire Units 1 and 2 Page R - 7 Supplement 10