ML22299A181
| 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
2 Agenda
- Introductions
- Overview of TSTF-107-A
- Technical Specification (TS) 3.1.5 Variation
- Proposed TS Changes
- Submittal Timeline
3 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
4 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)
5 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
6 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.
7 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
8 Proposed TS Changes
9 Proposed TS Changes
10 Proposed TS Changes
11 Proposed TS Changes
12 Submittal Timeline
- Target submittal in November 2022
- Requesting one year review and approval
- 90-day implementation following approval
Questions