ML22299A181

Presubmittal Meeting Presentation - License Amendment Request - Adoption of TSTF-107-A Separate Control Rods That Are Untrippable Versus Inoperable and Change to TS 3.1.5 Condition B (EPID: L?2021?LRM-0081)

ML22299A181
Person / Time
Site:	Palo Verde
Issue date:	10/26/2022
From:	Dennis Galvin, Siva Lingam Plant Licensing Branch IV
To:
Lingam S, 301-415-1564
References
EPID: L?2021?LRM-0081)
Download: ML22299A181 (1)

Text

License Amendment Request - Adoption of TSTF-107-A Separate Control Rods that are Untrippable versus Inoperable and Change to TS 3.1.5 Condition B Pre-Submittal Meeting October 27, 2022

Agenda

• Introductions

• Overview of TSTF-107-A

• Technical Specification (TS) 3.1.5 Variation

• Proposed TS Changes

• Submittal Timeline 2

Overview of TSTF-107-A

• TSTF-107-A revises TS 3.1.5 LCO Statement, Conditions A, C and D to correct ambiguity regarding control rods that are inoperable vs. out of alignment The LCO statement is revised to clarify that the alignment limit is separate from the operability of the rod Conditions A and D - removes 'trippable and so misaligned CEAs require entry into Condition A and D and completion of their respective REQUIRED ACTION Condition C - replaces 'untrippable' with inoperable to address trippable, but slow CEAs that are inoperable Specific CEA misalignment values and completion times are not changed Condition D plant trip Action not changed Conforming TS Bases Changes consistent with TSTF-107-A 3

Overview of TSTF-107-A

• Changes are similar to the approved Combustion Engineering (CE)

Standard Technical Specifications (STS) (NUREG-1432, Revision 5)

The approved CE STS have similar Actions but are designated as Conditions A and B

• Current PVNGS TS 3.1.5 based upon CE STS (NUREG-1432) Revision 1 (LA 117, ADAMS Accession No. ML021720060), which predated TSTF-107-A PVNGS TS 3.1.5 Conditions B and D are different than the CE STS and TSTF-107-A Condition B addresses CEA position indication Condition D directs opening of the reactor trip breakers if two or more CEAs are misaligned by more than the specified limit (Plant trip action not in TSTF-107-A) 4

TS 3.1.5 Variation

• Revises TS 3.1.5, Condition B - provides action for limited duration loss of some position indication for multiple CEAs

• Condition B artifact of Old TS, not TSTF-107 or CE-STS

• With LCO 3.1.5 not met, and no Action provided, LCO 3.0.3 requires placement of unit outside mode of applicability (Modes 1 and 2)

• Change to TS 3.1.5, Condition B improves readability for Operators 5

TS 3.1.5 Variation TS Bases for 3.1.5, Condition B At least two of the following three CEA position indicator channels shall be OPERABLE for each CEA:

a. CEA Reed Switch Position Transmitter (RSPT 1) with the capability of determining the absolute CEA positions within 5.2 inches,

b. CEA Reed Switch Position Transmitter (RSPT 2) with the capability of determining the absolute CEA positions within 5.2 inches, and

c. The CEA pulse counting position indicator channel.

Additionally, the Upper Electrical Limit (UEL) CEA reed switches provide an acceptable indication of CEA position for a fully withdrawn condition.

6

TS 3.1.5 Variation

• Unlikely but credible single failure could result in more than one CEA per group having only one OPERABLE position indicator channel - loss of a vital instrument bus (PNC-D27 or PND-D28)

• Each CEA still has at least one OPERABLE position indicator channel to confirm the required LCO initial conditions New Advanced Rod Control Hybrid (ARCH) / Ovation modification is designed such that CEA pulse counts are retained, therefore having two OPERABLE position indicator channels.

• 6-hour completion time to restore the CEA indicator channel preferable to LCO 3.0.3 entry with potential CEA movement during shutdown 7

Proposed TS Changes 8

Proposed TS Changes 9

Proposed TS Changes 10

Proposed TS Changes 11

Submittal Timeline

• Target submittal in November 2022

• Requesting one year review and approval

• 90-day implementation following approval 12

Questions