Text

Application to Revise Technical Specifications to Adopt TSTF-234-A, Revision 1, Add Action for More than One (D)Rpi Inoperable
	ML24149A117
Person / Time
Site:	Catawba, Harris, Robinson
Issue date:	05/23/2024
From:	Gibby S; Duke Energy, Duke Energy Carolinas, Duke Energy Progress
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RA-23-0028
	Download: ML24149A117 (1)
	v • d • e

SHAWN K. GIBBY Vice President Nuclear Engineering 13225 Hagers Ferry Rd.

Huntersville, NC 28078 704 519-5138 Shawn.Gibby@duke-energy.com 10 CFR 50.90 May 23, 2024 Serial: RA-23-0028 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Catawba Nuclear Station, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. NPF-35 and NPF-52 Docket Nos. 50-413 and 50-414 Shearon Harris Nuclear Power Plant, Unit No. 1 Renewed Facility Operating License No. NPF-63 Docket No. 50-400 H. B. Robinson Steam Electric Plant, Unit No. 2 Renewed Facility Operating License No. DPR-23 Docket No. 50-261

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-234-A, Revision 1, Add Action for More Than One [D]RPI Inoperable Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as Duke Energy, is submitting a request for an amendment to the Technical Specifications (TS) for Catawba Nuclear Station, Unit Nos. 1 and 2 (CNS);

Shearon Harris Nuclear Power Plant, Unit No. 1 (HNP); and H. B. Robinson Steam Electric Plant, Unit No. 2 (RNP).

The proposed amendment would modify CNS TS 3.1.7, Rod Position Indication, RNP TS 3.1.7, Rod Position Indication, and HNP TS 3.1.3.2, Position Indication Systems - Operating, to add a Condition (Action for HNP) for more than one inoperable rod position indication per group. For CNS and RNP only, the proposed amendment would also modify the Action Note and provide clarification to the existing Required Actions A.1 and B.1. These proposed changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-234-A, Add Action for More Than One [D]RPI Inoperable, Revision 1 (ADAMS Accession No. ML040580468). provides a description and assessment of the proposed changes. Enclosure 2 provides the existing TS pages marked to show the proposed changes. Enclosure 3 provides existing TS Bases pages marked to show the proposed changes, for information only.

U.S. Nuclear Regulatory Commission RA-23-0028 Page 2 Approval of the proposed amendment is requested within one year of completion of the NRC's acceptance review. Once approved, the amendment shall be implemented within 120 days.

In accordance with 10 CFR 50.91, Duke Energy is providing a copy of the proposed license amendment to the designated representatives for the States of North Carolina and South Carolina.

This document contains no regulatory commitments.

If you should have any questions regarding this submittal, or require additional information, please contact Ryan Treadway, Director - Nuclear Fleet Licensing, at (980) 373-5873.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 23, 2024.

Sincerely, Shawn Gibby

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Proposed Technical Specification Bases Changes (Mark-up) - For Information Only

U.S. Nuclear Regulatory Commission RA-23-0028 Page 3 cc:

L. Dudes, USNRC, Region II Regional Administrator L. Haeg, USNRC NRR Project Manager for RNP S. Williams, USNRC NRR Project Manager for CNS M. Mahoney, USNRC NRR Project Manager for HNP C. Rivard, USNRC Senior Resident Inspector for CNS P. Boguszewski, USNRC Senior Resident Inspector for HNP J. Zeiler, USNRC Senior Resident Inspector for RNP NC Utilities Commission (swatson@ncuc.net)

L. Brayboy (Louis.Brayboy@dhhs.nc.gov), NC DHHS, Manager - Radioactive Materials Branch SC Attorney General (HKirkland@scag.gov)

S. Jenkins (jenkinse@dhec.sc.gov), Chief - Bureau of Radiological Health N. Gauthier (gauthinl@dhec.sc.gov), Manager - Nuclear Response Section

RA-23-0028 Page 1 of 6 Description and Assessment

RA-23-0028 Page 2 of 6

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as Duke Energy, is submitting a request for an amendment to the Technical Specifications (TS) for Catawba Nuclear Station, Unit Nos. 1 and 2 (CNS);

Shearon Harris Nuclear Power Plant, Unit No. 1 (HNP); and H. B. Robinson Steam Electric Plant, Unit No. 2 (RNP).

The proposed amendment would modify CNS TS 3.1.7, Rod Position Indication, RNP TS 3.1.7, Rod Position Indication, and HNP TS 3.1.3.2, Position Indication Systems - Operating, to add a Condition (Action for HNP) for more than one inoperable rod position indication (RPI) per group. For CNS and RNP only, the proposed amendment would also modify the Action Note and provide clarification to the existing Required Actions A.1 and B.1. These proposed changes are consistent with NRC-approved Technical Specifications Task Force (TSTF)

Traveler TSTF-234-A, Add Action for More Than One [D]RPI Inoperable, Revision 1 (ADAMS Accession No. ML040580468). The proposed changes will better align CNS, HNP and RNP with NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 5.

2.0 ASSESSMENT

2.1

System Description

The axial position of shutdown rods and control rods are determined by two separate and independent systems: the Bank Demand Position Indication System (commonly called group step counters) and the Rod Position Indication (RPI) System.

The Bank Demand Position Indication System counts the pulses from the Rod Control System that move the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise (+/- 1 step or +/- 5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.

The RPI System provides a highly accurate indication of actual control rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center to center distance of 3.75 inches, which is 6 steps.

2.2 Summary of the Approved TSTF-234-A Traveler Justification Per TSTF-234-A, Revision 1, the proposed change adds a new Condition (Action for HNP),

which applies when more than one RPI per group is inoperable. The proposed change allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore all but one RPI per group. The additional time to restore an inoperable RPI is appropriate because the proposed Actions would require that the control rods be under manual control, that Reactor Coolant System average temperature be monitored and recorded hourly, and that rod position be verified indirectly every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months using the movable incore

RA-23-0028 Page 3 of 6 detectors, thereby assuring that the rod alignment and rod insertion limiting conditions for operation (LCO) are met. Therefore, the required shutdown margin would be maintained with the proposed change. Given the alternate position monitoring requirement, and other indirect means of monitoring changes in rod position (e.g., alarms on Reactor Coolant System average temperature deviation), a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time to restore all but one RPI per group provides sufficient time to restore operability while minimizing shutdown transients during the time that the position indication system is degraded.

2.3 Variations Duke Energy is proposing the following variations from the TS changes described in TSTF-234-A, Revision 1:

1. The CNS, RNP, and HNP TS utilize different numbering and naming than the Standard Technical Specifications (STS) provided in NUREG-1431 on which TSTF-234-A was based. Specifically, the numbering and naming differences are:

TSTF-234-A Westinghouse Owner's Group (WOG) STS (Rev. 1)

Corresponding CNS TS Corresponding RNP TS Corresponding HNP TS 3.1.8, "Rod Position Indication" 3.1.7 3.1.7 3.1.3.2, Position Indication Systems

- Operating These differences are administrative and do not affect the applicability of TSTF-234-A to the CNS, RNP, and HNP TS.

2. TSTF-234-A contains the bracketed text [, or B.1, as applicable] in the TS Bases discussion for Condition C. This change is not adopted because it is not necessary to provide direction in the TS Bases that all applicable Conditions must be entered.

3. RNP TS 3.1.7 contains a footnote for current Condition C (One demand position indicator per bank inoperable for one or more banks.*). The footnote was only applicable during RNP Cycle 25, and therefore needs to be removed from TS. This variation is administrative and does not affect the applicability of TSTF-234-A to the RNP TS.

4. The TSTF mark-up is based on the STS in NUREG-1431, Revision 1 (April 1995), which includes Conditions, Required Actions and Completion Times; whereas the HNP TS are based upon the format and content of the NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," series, which utilize Actions that are a combination of all three of these (note that Completion Times are referred to as allowed outage times (AOTs) for HNP). These differences are administrative and do not affect the applicability of TSTF-234-A to the HNP TS.

5. HNP TS 3.1.3.2, Action a uses the terminology bank instead of group. This difference is administrative and does not affect the applicability of TSTF-234-A to the HNP TS.

6. HNP TS 3.1.3.2 currently does not have a default Action to be in MODE 3 (i.e., HOT STANDBY in the HNP TS) when the required Action and associated Completion Time

RA-23-0028 Page 4 of 6 are not met, as reflected in the TS mark-up for TSTF-234-A and in the STS for Westinghouse plants. For the proposed Action of more than one RPI per bank inoperable, a default to be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is added for situations where any of the proposed remedial actions and associated AOT is not met.

This added default has the effect of entering a Mode in which the requirement does not apply if the remedial actions cannot be completed within the associated AOT. The AOT of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, for reaching HOT STANDBY from full power conditions in an orderly manner and without challenging plant systems.

7.

HNP TS 3.1.3.2 does not contain a Note modifying the Actions to indicate that a separate entry is allowed for each inoperable rod position indicator. Therefore, the change described in TSTF-234-A to clarify the Note is not necessary for HNP.

8.

One of the changes in TSTF-234-A is to clarify that the position of the rods with inoperable position indicators can be verified indirectly with movable incore detectors as one of the remedial actions. For HNP only, the word indirectly is already in TS 3.1.3.2 Action a.1 for one RPI per bank inoperable. Therefore, this clarification change from TSTF-234-A is not applicable to the HNP TS.

These variations do not affect the applicability of TSTF-234-A and its NRC-approved justification to the CNS, RNP, and HNP TS.

2.4 Precedent The NRC staff approved changes to the TS for Vogtle Electric Generating Plant, Units 1 and 2, that are consistent with TSTF-234-A by letter dated June 9, 2016 (ADAMS Accession No. ML15132A569).

The NRC staff approved changes to the TS for McGuire Nuclear Station, Units 1 and 2, that are consistent with TSTF-234-A by letter dated November 19, 2018 (ADAMS Accession No. ML18277A322).

3.0 REGULATORY ANALYSIS

3.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements are applicable to the proposed change.

The regulations at Title 10 of the Code of Federal Regulations (10 CFR) Part 50.36, Technical specifications, establish the requirements related to the content of TS. Section 50.36(c)(2) states:

Limiting conditions for operation. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the

RA-23-0028 Page 5 of 6 licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The proposed change, which is consistent with TSTF-234-A, allows for more than one RPI in a group to be inoperable for a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , provided that other indirect means of monitoring changes in rod position are available. This is in alignment with the remedial actions and CT provided by the associated STS in NUREG-1431 for Westinghouse plants. Therefore, the requirements of 10 CFR 50.36 will continue to be met for the proposed change.

The proposed change does not affect compliance with these regulatory requirements and will continue to ensure that the lowest functional capabilities or performance levels of equipment required for safe operation are met.

3.2 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as Duke Energy, is submitting a request for an amendment to the Technical Specifications (TS) for Catawba Nuclear Station, Unit Nos. 1 and 2 (CNS);

Shearon Harris Nuclear Power Plant, Unit No. 1 (HNP); and H. B. Robinson Steam Electric Plant, Unit No. 2 (RNP).

The proposed amendment would modify CNS TS 3.1.7, Rod Position Indication, RNP TS 3.1.7, Rod Position Indication, and HNP TS 3.1.3.2, Position Indication Systems - Operating, to add a Condition (Action for HNP) for more than one inoperable rod position indication per group. For CNS and RNP only, the proposed amendment would also modify the Action Note and provide clarification to the existing Required Actions A.1 and B.1. These proposed changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-234-A, Add Action for More Than One [D]RPI Inoperable, Revision 1 (ADAMS Accession No. ML040580468).

Duke Energy has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment provides a Condition and Required Actions for more than one inoperable RPI per rod group. The RPls are not an initiator of any accident previously evaluated. The RPls are one indication used by operators to verify control rod insertion following an accident; however other indications are available. Therefore, allowing a finite period of time to correct more than one inoperable RPI prior to requiring a plant shutdown will not result in an increase in the consequences of any accident previously evaluated. The proposed amendment does not involve an increase in the probability or consequences of any accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

RA-23-0028 Page 6 of 6 Response: No The proposed amendment does not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation. The changes do not alter the assumptions made in the safety analysis. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed amendment provides time to correct the condition of more than one RPI inoperable in a rod group. Compensatory measures are required to verify that the rods monitored by the inoperable RPls are not moved to ensure that there is no effect on core reactivity. Requiring a plant shutdown with inoperable RPIs introduces plant risk and should not be initiated unless the RPI cannot be repaired in a reasonable period. As a result, the safety benefit provided by the proposed Condition (Action for HNP) offsets the small decrease in safety resulting from continued operation with more than one inoperable RPI. Therefore, the proposed amendment does not involve a reduction in a margin of safety.

Based on the above, Duke Energy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

3.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

RA-23-0028 Proposed Technical Specification Changes (Mark-Up)

Rod Position Indication 3.1.7 Catawba Units 1 and 2 3.1.7-1 Amendment Nos. 173/165 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCO 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS

NOTE----------------------------------------------------------

Separate Condition entry is allowed for each inoperable rod position indicator per group and each demand position indicator per bank.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One DRPI per group inoperable for one or more groups.

A.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.

OR A.2 Reduce THERMAL POWER to < 50% RTP.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 8 hours B.

More than one DRPI per group inoperable.

B.1 Place the control rods under manual control.

AND B.2 Monitor and Record RCS Tavg.

AND Immediately Once per 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

Rod Position Indication 3.1.7 ACTIONS (continued)

Catawba Units 1 and 2 3.1.7-2 Amendment Nos. 173/165 CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued)

B.3 AND B.4 Verify the position of the rods with inoperable position indicators indirectly by using the movable incore detectors.

Restore inoperable position indicators to OPERABLE status such that a maximum of one DRPI per group is inoperable.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 24 hours BC.

One or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the last determination of the rod's position.

BC.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.

OR BC.2 Reduce THERMAL POWER to < 50% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 8 hours (continued)

Rod Position Indication 3.1.7 ACTIONS (continued)

Catawba Units 1 and 2 3.1.7-3 Amendment Nos. XXX/XXX CONDITION REQUIRED ACTION COMPLETION TIME CD.

One demand position indicator per bank inoperable for one or more banks.

CD.1.1 Verify by administrative means all DRPIs for the affected banks are OPERABLE.

AND CD.1.2 Verify the most withdrawn rod and the least withdrawn rod of the affected banks are

< 12 steps apart.

OR CD.2 Reduce THERMAL POWER to < 50% RTP.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 8 hours DE.

Required Action and associated Completion Time not met.

DE.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.

Once prior to criticality after each removal of the reactor head

R EACTIVITY CONTROL SYSTEMS P OSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.3.2 The Digital Rod Position Indication System and the Demand Position Indication System shall be OPERABLE and capable of determining the shutdown and control rod positions within +/- 12 steps.

A PPLICABILITY: MODES 1 and 2.

AACTION:

a.

With a maximum of one digital rod position indicator per bank inoperable either:

1.

Determine the position of the nonindicating rod(s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and immediately after any motion of the nonindicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or 2.

Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b.

With more than one digital rod position indicator per bank inoperable either:

1.a) Place the control rods under manual control immediately, and b) Monitor and record Reactor Coolant System average temperature (Tavg) at least once per hour, and c) Determine the position of the nonindicating rods indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and immediately after any motion of the nonindicating rods which exceeds 24 steps in one direction since the last determination of the rod positions, and d) Restore the inoperable digital rod position indicators to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months such that a maximum of one digital rod position indicator per bank is inoperable, or 2.

Be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

bc. With a maximum of one demand position indicator per bank inoperable either:

1.

Verify that all digital rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of 12 steps of each other at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or 2.

Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

SURVEILLANCE REQUIREMENTS 4.1.3.2 Each digital rod position indicator shall be determined to be OPERABLE by verifying that the Demand Position Indication System and the Digital Rod Position Indication System agree within 12 steps at the frequency specified in the Surveillance Frequency Control Program except during time intervals when the rod position deviation monitor is inoperable, then compare the Demand Position Indication System and the Digital Rod Position Indication System at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SHEARON HARRIS - UNIT 1 3/4 1-17 Amendment No. 1 54

Rod Position Indication 3.1.7 HBRSEP Unit No. 2 3.1-15 Amendment No. 2 33 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCO 3.1.7 The Analog Rod Position Indication (ARPI) System and the Demand Position Indication System shall be OPERABLE.

Note Individual Rod Position Indicators may be outside their limits for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following substantial rod movement.

APPLICABILITY:

MODES 1 and 2.

ACTIONS NOTE Separate Condition entry is allowed for each inoperable rod position indicator p er group and each demand position indicator per bank.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One ARPI per group inoperable for one or more groups.

A.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months O R A.2 Reduce THERMAL POWER to < 50% RTP.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months B.

More than one ARPI per group inoperable.

B.1 A ND B.2 A ND Place the control rods under manual control.

Monitor and Record RCS Tavg.

Immediately Once per 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

Rod Position Indication 3.1.7 HBRSEP Unit No. 2 3.1-15 Amendment No. 2 33 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued)

B.3 Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months A ND B.4 Verify the position of the rods with inoperable position indicators indirectly by using the movable incore detectors.

Restore inoperable position indicators to OPERABLE status such that a maximum of one ARPI per group is inoperable.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B C. One or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the last determination of the rod's position.

B C.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.

O R 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (continued)

Rod Position Indication 3.1.7 HBRSEP Unit No. 2 3.1-16 Amendment No. 2 17 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B C.

(continued)

B C.2 Reduce THERMAL POWER to 50% RTP.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months C D. One demand position indicator per bank inoperable for one or more banks.*

C D.1.1 Verify by administrative means all ARPIs for the affected banks are OPERABLE.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (continued)

DELETE

AND C D.1.2 NOTE Only required to be met for bank positions < 200 steps.

Verify the position of each rod in the affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s).

AND

During Cycle 25, the condition of two demand position indicators per bank inoperable for onr or m

ore banks is allowed with a required action to restore one demand position indicator per bank a nd a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Rod Position Indication 3.1.7 HBRSEP Unit No. 2 3.1-17 Amendment No. 1 76 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C D. (continued)

C D.1.3

NOTE-----------

Only required to be met for bank positions 200 steps.

Verify the position of each rod in the affected bank(s) is within 15 inches of the bank demand position.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months O R C D.2 Reduce THERMAL POWER to 50% RTP.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D E.

Required Action and associated Completion Time not met.

D E.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

RA-23-0028 Proposed Technical Specification Bases Changes (Mark-up) - For Information Only

Rod Position Indication B 3.1.7 Catawba Units 1 and 2 B 3.1.7-4 Revision No. 23 BASES LCO (continued) power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.

APPLICABILITY The requirements on the DRPI and step counters are only applicable in MODES 1 and 2 (consistent with LCO 3.1.4, LCO 3.1.5, and LCO 3.1.6),

because these are the only MODES in which power is generated, and the OPERABILITY and alignment of rods have the potential to affect the safety of the plant. In the shutdown MODES, the OPERABILITY of the shutdown and control banks has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the Reactor Coolant System.

ACTIONS The ACTIONS table is modified by a Note indicating that a separate Condition entry is allowed for each inoperable rod position indicator p er g roup and each demand position indicator per bank. This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator.

A.1 When one DRPI channel Data A and Data B per group fails, the position of the rod c an may still be determined indirectly by use of the movable incore m ovable detectors. The Required Action may also be satisfied by ensuring at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months that FQ satisfies LCO 3.2.1, FH satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Based on experience, normal power operation does not require excessive movement of banks. If a bank has been significantly moved, the Required Action of B C.1 or B C.2 below is required. Therefore, verification of RCCA position within the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.

A.2 Reduction of THERMAL POWER to 50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors (Ref. 4).

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on operating experience, for reducing power to 50% RTP from full power

Rod Position Indication B 3.1.7 BASES ACTIONS (continued)

Catawba Units 1 and 2 B 3.1.7-5 Revision No. 23 H

conditions without challenging plant systems and allowing for rod position determination by Required Action A.1 above.

B.1 When more than one DRPI per group fails, additional actions are necessary to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are limited. Placing the Rod Control System in manual assures unplanned rod motion will not occur. Placing the Rod Control System in manual together with the indirect position determination available via movable incore detectors will minimize the potential for rod misalignment. The immediate Completion Time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this Condition.

B.2 Monitoring and recording reactor coolant Tavg helps assure that significant changes in power distribution and SDM are avoided. The once per hour Completion Time is acceptable because only minor fluctuations in RCS temperature are expected at steady state plant operating conditions.

B.3 The position of the rods may be determined indirectly by use of the movable incore detectors. The Required Action may also be satisfied by ensuring at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months that FQ satisfies LCO 3.2.1, FN satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Verification of RCCA position once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing continued full power operation for a limited, 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.

B.4 The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides sufficient time to troubleshoot and restore the DRPI system to operation while avoiding the plant challenges associated with a shutdown without full rod position indication (Ref. 4).

Rod Position Indication B 3.1.7 BASES ACTIONS (continued)

Catawba Units 1 and 2 B 3.1.7-6 Revision No. 23 Based on operating experience, normal power does not require excessive rod movement. If one or more rods has been significantly moved, the Required Action of C.1 or C.2 below is required.

B C. 1 and B C. 2 These Required Actions clarify that when one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction, since the position was last determined, the Required Actions of A.1 and A.2 are still appropriate but must be initiated promptly under Required Action B C.1 to begin verifying that these rods are still properly positioned, relative to their group positions.

If, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the rod positions have not been determined, THERMAL POWER must be reduced to 50% RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to avoid undesirable power distributions that could result from continued operation at > 50% RTP, if one or more rods are misaligned by more than 24 steps.

The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable period of time to verify the rod positions.

C D. 1.1 and C D. 1.2 With one demand position indicator per bank inoperable, the rod positions can be determined by the DRPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE and the most withdrawn rod and the least withdrawn rod are 12 steps apart within the allowed Completion Time of once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate.

Since DRPI is the only operable rod position indication, administrative means are actions taken by the control room SRO to assure that the DRPI for the affected bank remains operable at all times. These administrative means would prevent any maintenance or testing of the operable DRPI for the affected bank until the inoperable demand position indicator is returned to operable status.

C D. 2 Reduction of THERMAL POWER to 50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factor limits (Ref. 4). The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provides an acceptable period of time to verify the rod positions per Required Actions CD.1.1 and CD.1.2 or reduce power to < 50% RTP.

Catawba Units 1 and 2 B 3.1.7-7 Revision No. 23 BASES Rod Position Indication B 3.1.7 ACTIONS (continued)

D E..1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.1.7.1 REQUIREMENTS Verification that the DRPI agrees with the demand position within 12 steps ensures that the DRPI is operating correctly.

This Surveillance is performed prior to reactor criticality after each removal of the reactor head as there is the potential for unnecessary plant transients if the SR were performed with the reactor at power.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 13.

2.

UFSAR, Section 15.0.

3.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

4.

UFSAR, Section 15.4.

Rod Position Indication B 3.1.7 BASES (continued)

HBRSEP Unit No. 2 B 3.1-45 Revision No. 56 LCO OPERABILITY of the position indicator channels ensures that (continued) inoperable, misaligned, or mispositioned control rods can be detected.

Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.

This LCO is modified by a note indicating individual control rod position indications may not be within limits for up to and including one hour following substantial control rod movement. This allows up to one hour of thermal soak time to allow the control rod drive shaft to reach thermal equilibrium and thus present a consistent position indication. Substantial rod movement is considered to be 10 or more steps in one direction in less than one hour.

In accordance with this note, the comparison of the bank demand position and the RPI may take place at any time up to one hour after rod motion, at any power level. Based on this allowance, rod position may be considered within limits during the thermal soak time to allow position indication to stabilize.

APPLICABILITY The requirements on the ARPI and step counters are only applicable in MODES 1 and 2 (consistent with LCO 3.1.4, LCO 3.1.5, and LCO 3.1.6),

because these are the only MODES in which power is generated, and the OPERABILITY and alignment of rods have the potential to affect the safety of the plant. In the shutdown MODES, the OPERABILITY of the shutdown and control banks has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the Reactor Coolant System.

ACTIONS The ACTIONS table is modified by a Note indicating that a separate Condition entry is allowed for each inoperable rod position indicator per group and each demand position indicator per bank. This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator.

Rod Position Indication B 3.1.7 BASES (continued)

HBRSEP Unit No. 2 B 3.1-45a Revision No. 56 ACTIONS A.1 (continued)

When one ARPI channel per group fails, the position of the rod can may still be determined indirectly by use of the movable incore movable detectors. The Required Action may also be satisfied by ensuring at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months that FQ satisfies LCO 3.2.1, FH satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Based on experience, normal power operation does not require excessive movement of banks.

If a bank has been significantly moved, the Required Action of BC.1 or BC.2 below is required. Therefore, verification of RCCA position within the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.

Rod Position Indication B 3.1.7 BASES (continued)

HBRSEP Unit No. 2 B 3.1-46 Revision No. 36 ACTIONS A.2 (continued)

Reduction of THERMAL POWER to 50% RTP more than offsets the increase in core FQ and FN H due to rod position. The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on operating experience, for reducing power to 50% RTP from full power conditions without challenging plant systems and allowing for rod position determination by Required Action A.1 above.

B.1 When more than one ARPI per group fails, additional actions are necessary to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are limited. Placing the Rod Control System in manual assures unplanned rod motion will not occur. Placing the Rod Control System in manual together with the indirect position determination available via movable incore detectors will minimize the potential for rod misalignment. The immediate Completion Time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this Condition.

B.2 Monitoring and recording reactor coolant Tavg helps assure that significant changes in power distribution and SDM are avoided. The once per hour Completion Time is acceptable because only minor fluctuations in RCS temperature are expected at steady state plant operating conditions.

B.3 The position of the rods may be determined indirectly by use of the movable incore detectors. The Required Action may also be satisfied by ensuring at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months that FQ satisfies LCO 3.2.1, FN H

satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Verification of RCCA position once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing continued full power operation for a limited, 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.

Rod Position Indication B 3.1.7 BASES (continued)

HBRSEP Unit No. 2 B 3.1-46a Revision No. 56 ACTIONS B.4 (continued)

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides sufficient time to troubleshoot and restore the ARPI system to operation while avoiding the plant challenges associated with a shutdown without full rod position indication (Ref. 3).

Based on operating experience, normal power operation does not require excessive rod movement. If one or more rods has been significantly moved, the Required Action of C.1 or C.2 below is required.

BC.1 and BC.2 These Required Actions clarify that when one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction, since the position was last determined, the Required Actions of A.1 and A.2 are still appropriate but must be initiated promptly under Required Action BC.1 to begin verifying that these rods are still properly positioned, relative to their group positions.

If, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the rod positions have not been determined, THERMAL POWER must be reduced to 50% RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to avoid undesirable power distributions that could result from continued operation at > 50% RTP, if one or more rods are misaligned by more than 24 steps.

The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable period of time to verify the rod positions.

CD.1.1, CD.1.2, and CD.1.3 Condition C is modified by a footnote that provides a condition for two demand position indicators per bank to be inoperable for one or more banks. The footnote states that the required action is restoration of one demand position indicator per bank and a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

When one or more demand position indicators are inoperable in one or more banks, Condition C is entered. If two demand position indicators are inoperable in a bank, the footnote required action and completion time are applied. After expiration of the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months completion time associated with the footnote condition, Required Action D.1 to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is required to be entered. Additionally, during the time when two demand indicators per bank are inoperable, Required Action C.1.3 cannot be completed. Expiration of the C.1.3 completion time will require entry into Required Action D.1 to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Required Action D.1 would be applicable

Rod Position Indication B 3.1.7 BASES (continued)

HBRSEP Unit No. 2 B 3.1-47 Revision No. 80 ACTIONS until power has been reduced to 50%, at which time the (continued)

Required Action C.2 would be met.

With one demand position indicator per bank inoperable, the rod positions can be determined by the ARPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE, that the position of each rod in the affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s), for bank positions < 200 steps and that the position of each rod in the affected bank(s) is within 15 inches of the bank demand position for bank positions 200 steps within the allowed Completion Time of once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate.

CD.2 Reduction of THERMAL POWER to 50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors. The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provides an acceptable period of time to verify the rod positions per Required Actions CD.1.1 and CD.1.2 or reduce power to 50% RTP.

DE.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.1.7.1 REQUIREMENTS A CHANNEL CALIBRATION of the ARPI System is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. The 24 month Frequency is based on the need to perform this Surveillance under conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

v t e Letter Sequence Request
EPID:L-2024-LLA-0077, TSTF-234 (Open)
Initiation Request Acceptance Administration Questions Answers Results Approval... Other: ML25086A296
MONTHYEAR2024-06-24 [Table View]

RA-23-0028, Application to Revise Technical Specifications to Adopt TSTF-234-A, Revision 1, Add Action for More than One (D)Rpi Inoperable

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RA-23-0028, Application to Revise Technical Specifications to Adopt TSTF-234-A, Revision 1, Add Action for More than One (D)Rpi Inoperable

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3.0 REGULATORY ANALYSIS

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