ML15365A610

TSTF Comments on Draft Model Safety Evaluation of Traveler TSTF-547, Revision 0, Clarification of Rod Position Requirements, and Transmittal of TSTF-547, Revision 1

ML15365A610
Person / Time
Site:	Technical Specifications Task Force
Issue date:	12/31/2015
From:	Clark J A, Gustafson O W, Hegrat H L, Morris J R B&W Pantex, BWR Owners Group, Combustion Engineering, PWR Owners Group, Technical Specifications Task Force, Westinghouse
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-15-13
Download: ML15365A610 (98)

Text

TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVIT YTSTF

Code of Federal Regulations

Technical Specifications Standard Review Plan

31-Dec-15 31-Dec-15 31-Dec-15 31-Dec-15

,

,

, and SR 3.2.2.1 5

---

NOTES---------------------------------- 1. Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.

[2. Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion.] -----------------------------------------------------------------

position of s

---

NOTE----------------------------------------------- Not applicable to shutdown banks inserted while performing SR 3.1.4.2.

---

A. One shutdown bank inserted [16] steps beyond the insertion limits specified in the COLR. A.1 Verify all control banks are within the insertion limits specified in the COLR.

AND A.2.1 Verify SDM is within the limits specified in the COLR.

OR

A.2.2 Initiate boration to restore SDM to within limit.

AND A.3 Restore the shutdown bank to within the insertion limits specified in the COLR.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> B

for reasons other than Condition AB

B

B

C

C

[---------------------------- NOTE ------------------------------ Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion. --------------------------------------------------------------------]

---

NOTE----------------------------------------------- Not applicable to control banks inserted while performing SR 3.1.4.2.

---

A. Control bank A, B, or C inserted [16] steps beyond the insertion, sequence, or overlap limits specified in the COLR. A.1 Verify all shutdown banks are within the insertion limits specified in the COLR.

AND A.2.1 Verify SDM is within the limits specified in the COLR.

OR

A.2.2 Initiate boration to restore SDM to within limit.

AND A.3 Restore the control bank to within the insertion, sequence, and limits specified in the COLR.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> B

B

for reasons other than

Condition A B

B

C for reasons other than Condition AC

C

C

DD

[---------------------------- NOTE ------------------------------ Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion. --------------------------------------------------------------------]

[---------------------------- NOTE ------------------------------ Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion. --------------------------------------------------------------------]

---

NOTE --------------------------------------------------- [Individual RPIs are not required to be OPERABLE for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following movement of the associated rods.] --------------------------------------------------------------------------------------------------

[D]RPI in

[D]RPI

OR A.2.1 Verify the position of the rods with inoperable [D]RPI indirectly by using the moveable incore detectors.

AND

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> AND Once per 31 EFPD thereafter

AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement

AND

A.2.2 Restore inoperable [D]RPI to OPERABLE status. 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> after each movement of rod with inoperable [D]RPI

> 12 steps

AND Prior to THERMAL

POWER exceeding 50% RTP AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP

Prior to entering MODE 2 from MODE 3 in one or more groups

2[D]RPIs

One or more [D]RPI inoperable in one or more groups and associated rod has

>

[D]RPIs

or more sin

---

NOTE----------------------------------- Not required to be met for [D]RPIs associated with rods that do not meet LCO 3.1.4. -----------------------------------------------------------------

e

e

.1 and B.1.2

5

the position of sis

The SR is modified by a Note that permits it to not be performed for rods associated with an inoperable demand position indicator or an inoperable rod position indicator. The alignment limit is based on the demand position indicator which is not available if the indicator is inoperable.

LCO 3.1.7, "Rod Position Indication," provides Actions to verify the rods are in alignment when one or more rod position indicators are inoperable.

---

Reviewer's Note ----------------------------------------

The bracketed SR Note is only applicable to plants with an analog rod position indication system. --------------------------------------------------------------------------------------------------

[The Surveillance is modified by a Note which states that the SR is not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion. Control rod temperature affects the accuracy of the rod position indication system. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows control rod temperature to stabilize following rod movement in order to ensure the indicated rod position is accurate.]

The LCO is modified by a Note indicating the LCO requirement is not applicable to shutdown banks being inserted while performing SR 3.1.4.2. This SR verifies the freedom of the rods to move, and may require the shutdown bank to move below the LCO limits, which would normally violate the LCO. This Note applies to each shutdown bank as it is moved below the insertion limit to perform the SR. This Note is not applicable should a malfunction stop performance of the SR.

A.1, A.2.1, A.2.2, and A.3

---

Reviewer's Note ------------------------------------- The bracketed number [16] in Condition A should be replaced with the plant-specific minimum number of steps that the rods must be moved to ensure correct performance of SR 3.1.4.2. ------------------------------------------------------------------------------------------------

If one shutdown bank is inserted less than or equal to [16] steps below the insertion limit, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to restore the shutdown bank to within the limit. This is necessary because the available SDM may be reduced with a shutdown bank not within its insertion limit. Also, verification of SDM or initiation of boration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1). If a shutdown bank is not within its insertion limit, SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.

While the shutdown bank is outside the insertion limit, all control banks must be within their insertion limits to ensure sufficient shutdown margin is available. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is sufficient to repair most rod control failures that would prevent movement of a shutdown bank.

B BB for reasons other than Condition A

CRequired Actions and associated Completion Times are not met,

---

Reviewer's Note ----------------------------------------

The bracketed SR Note is only applicable to plants with an analog rod position indication system.

---

[The Surveillance is modified by a Note which states that the SR is not required to be performed for shutdown banks until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after motion of rods in those banks. Rod temperature affects the accuracy of the rod position indication system. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes.

The one hour period allows rod temperature to stabilize following rod movement in order to ensure the indicated position is accurate.]

The LCO is modified by a Note indicating the LCO requirement is not applicable to control banks being inserted while performing SR 3.1.4.2. This SR verifies the freedom of the rods to move, and may require the control bank to move below the LCO limits, which would normally violate the LCO. This Note applies to each control bank as it is moved below the insertion limit to perform the SR. This Note is not applicable should a malfunction stop performance of the SR.

A.1, A.2.1, A.2.2, and A.3

---

Reviewer's Note ------------------------------------- The bracketed number [16] in Condition A should be replaced with the plant-specific minimum number of steps that encompasses the rod positions during performance of SR 3.1.4.2.

---

If Control Bank A, B, or C is inserted less than or equal to [16] steps below the insertion, sequence, or overlap limits, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to restore the control bank to within the limits. Verification of SDM or initiation of boration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1). If a control bank is not within its insertion limit, SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.

While the control bank is outside the insertion, sequence, or overlap limits, all shutdown banks must be within their insertion limits to ensure sufficient shutdown margin is available and that power distribution is controlled. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is sufficient to repair most rod control failures that would prevent movement of a shutdown bank.

Condition A is limited to Control banks A, B, or C. The allowance is not required for Control Bank D because the full power bank insertion limit can be met during performance of the SR 3.1.4.2 control rod freedom of movement (trippability) testing.

B BBC C

C for reasons other than Condition A

for reasons other than Condition A

D the

---

Reviewer's Note ---------------------------------------- The bracketed SR Note is only applicable to plants with an analog rod position indication system.

---

[The Surveillance is modified by a Note stating that the SR is not required to be performed for control banks until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after motion of rods in those banks. Control rod temperature affects the accuracy of the rod position indication system. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows control rod temperature to stabilize following rod movement in order to ensure the indicated rod position is accurate.]

---

Reviewer's Note ----------------------------------------

The bracketed SR Note is only applicable to plants with an analog rod position indication system. --------------------------------------------------------------------------------------------------

[The Surveillance is modified by a Note stating that the SR is not required to be performed for control banks until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after motion of rods in those banks. Control rod temperature affects the accuracy of the rod position indication system. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows control rod temperature to stabilize following rod movement in order to ensure the indicated rod position is accurate.]

e

---

Reviewer's Note ---------------------------------------- The bracketed LCO Note is only applicable to plants with an analog rod position indication system.

---

[The LCO is modified by a Note stating that the RPI system is not required to be met OPERABLE for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following movement of the associated rods. Control and shutdown rod temperature affects the accuracy of the RPI System. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows temperature to stabilize following rod movement in order to ensure the indicated position is accurate.]

, A.2.1, and A.2.2 in one or more groups

Required Action A.1 requires verification of the position of a rod with an inoperable [D]RPI once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> which may put excessive wear and tear on the moveable incore detector system, Required Action A.2.1 provides an alternative. Required Action A.2.1 requires verification of rod position using the moveable incore detectors every 31 EFPD, which coincides with the normal use of the system to verify core power distribution.

Required Action A.2.1 includes six distinct requirements for verification of the position of rods associated with an inoperable [D]RPI using the movable incore detectors:

a. Initial verification within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the inoperability of the [D]RPI;

b. Re-verification once every 31 Effective Full Power Days (EFPD) thereafter;

c. Verification within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if rod control system parameters indicate unintended rod movement. An unintended rod movement is defined as the release of the rod's stationary gripper when no action was demanded either manually or automatically from the rod control system, or a rod motion in a direction other than the direction demanded by the rod control system. Verifying that no unintended rod movement has occurred is performed by monitoring the rod control system stationary gripper coil current for indications of rod movement;

d. Verification within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if the rod with an inoperable [D]RPI is intentionally moved greater than 12 steps;

e. Verification prior to exceeding 50% RTP if power is reduced below 50% RTP; and

f. Verification within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of reaching 100% RTP if power is reduced to less than 100% RTP. Should the rod with the inoperable [D]RPI be moved more than 12 steps, or if reactor power is changed, the position of the rod with the inoperable

[D]RPI must be verified.

Required Action A.2.2 states that the inoperable [D]RPI must be restored to OPERABLE status prior to entering MODE 2 from MODE 3. The repair of the inoperable RPI must be performed prior to returning to power operation following a shutdown.

3

2 in one or more groups .

The inoperable [D]RPIs must be restored, such that a maximum of one [D]RPI per group is inoperable, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

With one [D]RPI inoperable in one or more groups and the affected groups have moved greater than 24 steps in one direction since the last determination of rod position, additional actions are needed to verify the position of rods within inoperable [D]RPI. Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the position of the rods with inoperable position indication must be determined using the moveable incore detectors to verify

or more s in one or more banks

The Surveillance is modified by a Note which states it is not required to be met for [D]RPIs associated with rods that do not meet LCO 3.1.4. If a rod is known to not to be within [12] steps of the group demand position, the ACTIONS of LCO 3.1.4 provide the appropriate Actions.