ML19340A249

Proposed Tech Spec Revisions

ML19340A249
Person / Time
Site:	Oconee
Issue date:	06/28/1974
From:	DUKE POWER CO.
To:
Shared Package
ML19340A248	List: ML19340A247 ML19340A249
References
NUDOCS 8001310540
Download: ML19340A249 (7)

Text

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14.1.2.7 Stuck-Out, Stuck-In, or Dropped-In Control Rod Accident 14.1.2.7.1 Identificatior, of Cause er In the event that a control rod cannot be moved, localized power peaking and suberitical margin must be considered.

If a control rod is dropped into the. core while operating, a rapid decrease in neutron power would occur, accompanied by a decrease in core average -

coolant temperature. In addition,.the power distribution might be distorted due to the new control rod pattern. In the presence of a distorted power

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distribution, the return to full power might lead to localized power densities and heat fluxes in excess of design limitations.

14.1.2.7.2 Protective Basis Adequate hot subcritical margin is provided by requiring a suberiticality of 1 percent ak/k with the control rod of greatest worth fully withdrawn from the core. The nuclear analysis reported in 3.2.2 demonstrates that this criterion can be satisfied. This criterion has been analyzed in terms of the minimum tripped rod worth available in the loss-of-coolant-flow, startup, rod with-drawal, and steam-line-failure accidents. In all cases, the available rod worth is sufficient to provide margins below any damage threshold.

For' protective purposes a dropped control rod is defined as the deviation of a control rod from its group reference position by more than a maximum of 9 inches. This definition then covers both the action of dropping a rod and sticking a rod while moving a group. The action taken by the ICS is:

a. All rod-out motion is inhibited,

b. The steam generator load demand is run back to 60 percent of rated load at 5%/s.

The details of these actions are described in Se :tian 7.2.2 and 7.2.3.

Although these ICS actions are available to mitigate the consequences of the accident, they are not required functions for-safe plant operation as the results of the accident analysis demonstrate.

The criterion for plant protection during this transient is that the DNB ratio wil not be less than 1.3 and the system pressure will not exceed code limits.

14.1.2.7.3 Method of Analysis The transient' response to a dropped control rod has been analyzed using a detailed B&W digital model. This program includes fuel pin, point kinetics,

. pressurizer, and loop models, including the steam generators.

-The' reactor is assumed to be operating at 100 percent of rated power when the control rod is dropped. In order.to achieve the most adverse response the most negative ' values of m: 1erator . coefficient [3.0 x 10-4 (ak/k)/F) and 5 Doppler coefficient [-1.3 x'10-5 (ak/k)/F) occurring at end-of-core life were gh 14-13 80 310 ,ge geyisca-Rev 34

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.used. The maximum rod worths expected to occur during full operation were used to examine the effects of ICS protective action. These rod worths

.- correspond to operation'at full power withor.t xenon (0.46% Ak/k) and with

,- xenon (0.36% Ak/k). It was assumed that the steam generator load demand was 1 reduced linearly'to 60. percent at 5%/s. The effects of a dropped. rod without ICS action were also examined for a very conservative rod worth of 0.65% Ak/k.

The rod was assumed to drop to 2/3 insertion in 1.4 seconds.

14.1.2.7.2 Results of Analysis The rese" the analysis with ICS action are presented in Figures 14-18 and 14-19. Figure .14-18 shows the: response to a 0.46% Ak/k dropped rod. The neutron power decreases rapidly to about 55 percent of rated power. This csuses rapid decreases in the core moderator temperature and fuel temperature, j'

These temperature decreases over-compensate for the worth of the control rod, and the power rises until the reduced steam generator demand begins to increase the inlet temperature and decreases the power.

The thermal power levels out j briefly at about 78 percent of its initial value but soon begins to decrease i- in response to the decreased steam generator demand. The pressurizer pressure swing is about + 60 psi before returning to equilibrium.

Figure 14-19 shows the results of the 0.36% Ak/k rod drop. The initial neutron

! -power decrease is slightly less in this case, resulting in the thermal power leveling off at 83 percent, a slightly higher value than in the 0.46% Ak/k case. The pressurizer .iressure peans at a higher value due to this higher thermal power.

, Figure 14-19a shows the results of a 0.65% Ak/k dropped rod analysis con-I servatively based on no ICS action and operation at higher than rated power

>\ level ~of 2772 mwt. The neutron power decreases causing a rapid decrease in

, both the core moderator temperature and the fuel temperature. These tem-

. perature decreases overcompensate for the worth of the control rod, and de neutron power rises slightly above the initial neutron power level. The neutron power then decreases to below the initial power level and eventually levels out at the initial power level. The thermal power. response is similar to the neutron power; however, the thermal power level never exceeds the j initial power value. Both the core moderator temperature and pressur2.zer j pressure decrease'during the transient and level out at a value lower than the initial value.

Several cases have been run for rod drops at beginning of life conditions.

These transients yield new powec levels that are lower than the end of life

-conditions and may result in reactor trip. These are therefore not included

.in'this discussion-because they represent less severe conditions.

f- 14.1.2.7 5 Conclusions Control rod malfunctions are accommodated by the core design without ICS action. Since the most severe case analyzed for the dropped rod does not p result'in reactor trip nor does the thermal power exceed its initial value,

core and reactor coolant system boundary protection.is assured. Additional protection for.the' dropped rod' accident is provided through the ICS which Ldetects a dropped rod and inhibits out-motion of the control rods. The ICS I 14-14 Entire Page Revised

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- thermal power will assume a lower value that matches the load demand and will j provide additional margin toward not exceeding any design limit.-

14.1.2.8- Loss of Electric Power 14.1.2.8.1 ldentification of Cause

- Each unit _is designed to withstand the effects of a loss of electric load or electric power. Emergency power systems are described in 8.2.3. Two types of power losses'are considered:

a. A loss of load condition, caused by separation of the unit from the

, transmission system.

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b. A hypothetical condition which results in a complete loss of all system and station power.

The reactor protection criteria for those conditions are that fuel damage will not-occur from an excessive power-to-flow ratio nor will the reactor coolant system pressure exceed design pressure.

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The Board has rejected it once here and an identical attampt, made in another proceeding, was also rejected by the Board therein. A list of the titles of all of Applicant's file folders is irrelevant and unduly burdensome since a description of ifle labels will'not facilitate the identification or the location of particular documents and since other, readily available-information will satisfy the Department's needs.

A. Applicant's Objections To The Information Which The Department Seeks Has Been Pre-viously Sustained By This Board.

Paragraph Two of the Special Request seeks to obtain a description of "the classifications or labels used to index or mark the files with the corresponding location or locations  !

l of the files so classified." The request is thus virtually

.dentical to Item 2 of the Joint Document Request ~1/ which the Board ruled many months ago to be improper under the Rules 1

(Tr. 152-153). At the Preliminary Conference which considered i Applicanc's objections, the Chairman of this Board made the i

following observations about the Department's request for a I

I 1/ Item 2 of the Joint Request states in full as follows:

"All file indexes and documents describing the filing ,

system utilized by the Company, its departments, divisions l and subunits, pertaining to active, inactive and stored l files and records."

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description of the Company's file folders:

MR. LECKIE: If Applicant has prepared a list including his 50,000 file titles, we would

'be ha'ppy to have that. -If not --

CHAIRMAN BENNETT: What do you want 50,000 titles for? You couldn't possibly make any use of it. (Tr. ~ 14 4)

CHAIRMAN DENNETT: One of the real problems in these-cases is the ;,ount of detailed information which is being prowesse<; here, which is holding up the proceedings.

Now, isn't there some practical way you can limit this? You don't want . ,,000 titles, that is ridiculous. (Tr. 145)

MR. LECKIE: We presume they don't have a list of that sort.

CHAIRMAN BENNETT: They undoubtedly have file folders, but I wouldn't order them to produce 50,000 i folders, that wouldn't make sense. (Tr. 145) 1/ The Chairmar also made the following observation con-cerning the suggestion that Applicant compile a special j list, as the Department now seeks: l You place a tremendous burden on'the l Applicant if you try to make him tell you all about everything in all of these i respects. How. I'think if.there is'some-thing that is elroady in existence that  ;

you want and they are willing to give it to you, that-is reasonable. If it helps you,Hif it helps you find evidence in the next go-around, fine.- But just to go through and find out matters of this character on the theory that maybe it might help sometime is going a little far.

(Tr . 149) [ Emphasis supplied].

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1/ l In the Consumers Power antitrust proceedings, the Board there dispcsed of the Department's efforts to obtain file index descriptions in a similtr sanner:

Applicant's first objection is to re-quest no. 2 -- file indexes and documents describing Applicant's filing system.

Unless we take the position that all of Applicant's files are relevant to the matters in controversy, a position we do not take, then this request calls for irrelevant material.

The Department of Justice argues that the data requested will enable it to locate relevant material. We do not agree. With the issues. clearly drawn, the Department should be able to frame requests appropriately limited to relevant material. Accordingly, Applicant's objection to this request is sustained.

Applicant submits that the reasoning contained is the above-quoted rulings by two Boards is irrefutable and that it applies with equal force to the interrogatory now pressed by th9 Department. Moreover, since the issue has been previously raised and resolved in this proceeding, elementary principles of res judicata compel denial of the Departnent's effort to re-try the matter at this j uncture.

While Applicant urges the Board to dispose of this matter simply on the basis of its prior rulings, we set out in the succeeding sections the reasons why the Departme:. 's

-1/ " Order Ruling on-Applicant's Objections . . .,

November 28, 1972, Consumers Power Company (Mid-land Plant, Units 1 and 2) (AEC Docket Nos. 50-329A, 50-330A), p. 2.

inquiry concerning file index descriptions is no more relevant and no-less burdensome than it was when it was originally re-jected by this Board.

B. To Require Applicant To Compile A List Of More Than Two Million File Index Descriptions Would Be Unreasonably Burdensome.

As the Commission's Rules recognize, this Board should protect parties to whom discovery is directed from " undue burden or expense." Section 2. 740 (c) . The attached affidavit of William L. Porter verifies that Applicant's files contain approximately 2.5 million file index descriptions.-1/ The Department's Special Request would have the Applicant investigate the content of each of its thousands of file drawers, then transcribe 2.5 million file folder descriptions, and finally, compile an elephantine list reflecting such descriptions. Such an undertaking, which would consume several months and countless manhours, surely constitutes an unconscionably burdensome and ,

unnecessary expenditure of time and money by the Applicant. j 1

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-1/ At the pre-hearing conference on November 17, 1972, i counsel for the Applicant gave the Board a rough guess that there would be 50,000 file folders (Tr. 144). This was done in response to the Board's inquiry at that time and without opportunity to consult the Company's officials. Subsequent inquiry has revealed that this

' figure was greatly underestimated. The 2.5 million figure cited in the text is an estimate by company officials familiar with the files. There are about 1.5 million file folders in the Charlotte headquarters alone.

6-The Board should protect the Applicant from such oppression.

See Evans v. Local U. 2127, Intn'l Brotherhood of Electrical Worksrs, 313 F.Supp. 1354 (N . D. Ga. 1969); Riss & Co. v.

Association of American Railroads, 23 F.R.D. 211 (D.D.C. 1959);

8 Wright and Miller, Federal Practice & Procedure, 52174 (1970 ed.), esp. cases cited in footnotes 91 and 92.

. Applicant, therefore, submits that the Department's inquiry concerning file folder descriptions must be denied as unreasonably burdensome and oppressive.

C. The Department's Inquiry About File Indexes Is Irrelevant Since It Will Not Satisy The Department's Purported Need. __

According to the Special Request, the Department seeks a description of each file folder in the Company's files in order to " facilitate the identification and location of a i

. . particular document," prczumably with regard to the second round of discovery (Special Regaest, para. 2; see also Tr. 884).

The basic fallacy in the Department's approach is that, as the i

Applicant's answer to t'le Special Request makes clear, the J l

decision as to where to file a given document is usually made l by the recipient or author of the document (or his secretary) and the Company has no standard policy or procedure concerning such filing. Thus, even with a detailed list containing thousands of file folder descriptions in hand, the Department

could not hope to determine in which folder a given document might be found.

Indeed, the Department must surely realize that the information sought is not needed in order to ascertain the location of particular documents. This inquiry is obviously pressed in the hope that the file titles niight give them some new avenues to explore. According to the Commission's Rules of Practice which govern the scope of discovery, interrogatories must be limited to a matter " relevant to the subject matter involved in the proceeding" and " reasonably calculated to lead to the discovery of admissible evidence." Section 2.740 (b) (1)  ;

1 of the Rules. See also Richland Wholesale Liquors v. Joseph E.

[

l Seagram and Scqs, 40 F.R.D. 480 (D.S.C. 1966). Moreover, the Commission has made clear that " fishing" expeditions are proscribed under this standard of relevance.Section IV (a) , Appendix A, of the Rules of Practice, 37 Fed. Reg. 15139 (1972). Since the inquiry which the Department makes will not " facilitate the identification or location" of documents or otherwise lead to the discovery of admissible evidence, it is clearly not relevant and must be denied.

l D. The Department's Allege' Need To Ascertain The Location Of Documents Can Be Satisfied By Other Means.

In response to that portion of the Special Request to which it does not object, Applicant has today supplied the

1 Department with a general description of its document filing I

i procedures. This description indicates that, except for the materials contained in the Applicant's " permanent" files, l

documents are usually located in files maintained by the  :

employee who created or received it-and are organized in his file as he deems mest appropriate.-1/

Thus, it is the identity of the document's author or recipient, not a file folder description, that may suggest in what files a given document could be found. To facilitate the location of documents in this regard, Applicant has today sup-plied the Department (and other counsel) with documents showing a complete description of the Company's management positions and chain of command and has specified the identity of the em-2/

playee occupying each such position.

Moreover, Applicant has expressed and here re-affirms its willingness to respond to any relevant inquiry about the existence or location of any particular document or documents (Tr. 885).

Thus, the material which Applicant has submitted will enable the Department to ascertain the identification and location of

-1/ Of course, in point of fact, of ten the file is maintained, and the particular filing system created, by such in-dividual's secretary.

2/ These documents, which include over 250 pages of material, were produced pursuant to the usual document production processes established by the parties. They are numbered 8130 to 8389.

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