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{{#Wiki_filter:}} | {{#Wiki_filter:i Attachment B Markups of Current Technical Specification Pages 9906240177 990616 T PDR ADOCK 05000293'- | ||
' P PDR I | |||
~ | |||
l TABLE OF CONTENTS 1.0 DEFINITIONS 1-1 2.0 SAFETY LIMITS 2-1 2.1 Safety Limits 2-1 2.2 Safety Limit Violation 2-1 BASES B2-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.1 REACTOR PROTECTION SYSTEM 4.1 3/4.1-1 BASES B3/4.1-1 3.2 PROTECTIVE INSTRUMENTATION 4.2 3/4.2 1 A. Primary Containment Isolation Functions A 3/4.2-1 B. Core and Containment Cooling Systems B 3/4.2-1 C. Control Rod Block Actuation C 3/4.2 2 ) | |||
D. Radiation Monitoring Systems D 3/4.2-2 E. Drywell Leak Detection j | |||
E 3/4.2-3 F. Surveillance Information Readouts F 3/4.2-3 G. Recirculation Pump Trip / Alternate Rod G Insertion 3/4.2-4 H. Drywell Temperature H 3/4.2-5 , | |||
BASES B3/4.2-1 ! | |||
3.3 REACTIVITY CONTROL . 4.3 3/4.3-1 A. Reactivity Margin - Core Loading? :ctMty A 3/4.3-1 L4m4ations B. Control Rod Operability B 3/4.3-2 C. Scram insertion Times C 3/4.3-7 D. Control Rod Accumulator D 3/4.3-8 E. Reactivity Anomalies E 3/4.3-10 F. Rod Worth Minimizer (RWM) .^! tem:tc F 9q@emente 3/4.3-11 G. Scram Discharge Volume G 3/4.3-12 H. Rod Pattem Control H 3/4.3-13 BASES B3/4.3-1 3.4 STANDBY LIQUID CONTROL SYSTEM 4.4 3/4.4-1 BASES B3/4.4-1 3.5 CORE AND CONTAINMENT COOLING 4.5 - 3/4.5-1 SYSTEMS A. Core Spray and LPCI Systems A 3/4.5-1 B. Containment Cooling System B 3/4.5-3 C. HPCI System C 3/4.5-7 D. Reactor Core isolation Cooling (RClC) System D 3/4.5-8 E. Automatic Depressurization System (ADS) E 3/4.5-9 F. Minimum Low Pressure Cooling and Diesel F Generator Availability 3/4.5-10 G. (Deleted) .. G 3/4.5-11 H. Maintenance of Filled Discharge Pipe H 3/4.5-12 BASES B3/4.5-1 PNPS i Amendment No. | |||
i | |||
ATTACHMENT B LIMITING CONDITIONS FOR OPERATI@ SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REACTIVITY CONTROL i..a mm,.1 _- ui.,.1... | |||
.m m, x__, | |||
.1_ u 2.m ,. 2. m_ | |||
7 - | |||
Applica-tc thc cpcrational status Applica to the cu:vcillancc cf thc control rad cystem. l rcquiremcat: ;f thc control rod ' | |||
# cystcr. | |||
-A< | |||
~ | |||
t< +0bicctivc. | |||
Obicet'cc. | |||
To cucure thc chility of 'hc eentrol rod syster tc control Tc vcrify th; chility of the rccctivity. control rod syster to contral v | |||
ICCCtr-itY-m m. .e r=_=t^r.._....._ _._ | |||
EccB ir" :cn-A "cccei.it, ' | |||
i-i r icn ;Ang l i Dr rti.it, Ii-itatime A. Reactivity maroin - core | |||
-+l A p2 " | |||
loadina - | |||
A. lhl Reactivity maroin - core | |||
> loadina I- The core loading shall be . | |||
0 33M limited to that which can be &# Sufficient control rods shall ' | |||
made subcritical in the most . | |||
be withdrawn following a reactive condition during the Aa' refueling outage when core Ap;- operating cycle with the alterations were performed to strongest operable control rod demonstrate with a margin of in its full-od position and 0.25 percent Ak that the core all other operable rods fully can be made subcritical at any | |||
, inserted, time in the subsequent fuel cycle with the strongest ib- necrti.it, marc:- i;ccerchie operable control rod fully en'-" - -t . withdrawn and all other | |||
% operable rods fully inserted. | |||
er Contrci rod drivcc which can .c bc mcvcd with control h "r"rt i cit- -- ;i- : m crabic red drive prcacurc cheH-be cor:rcl - "^ | |||
considerrd inopcrcbic. !f r s.c Insest i : . . , prrtially or fully .ithdrcun " Each particily or fully | |||
> W 8AB.1 ? + 3= | |||
control rad drive canact bc em"e.sau withdrawr operabic control rod ACTIONS A & S _____a a_. | |||
SR 4.8.813 ,m,u.._,.,. | |||
.a L_ , , , _ _ _ , A __, | |||
~.---..u. m m..._ | |||
.m __ _ _.m_ _. _-,o | |||
: m. -m ~~.m. um- m..m __,,_L. | |||
. ~ s. m -- | |||
prc0Curc thc rccctor chall 1ccot once cach .;cck.l Ec brought to a chutdowa T55t 511 bc per:crmcc{Tfne at condition withir 'O hours | |||
' tQ | |||
; 1 Coat encc pcr 2' hour; ir the unic3; ;nvc;tigation cvcnt pcucr opcratic. is demonstectcc that the cause continuing with tPrcc or marc the failurc la not duc to inopcrobic control rod; or in c failed contrel red drive the cvcat pcucr opcration la mechanium ccIlet 'cusing. continuing witt rne fully c: | |||
E Ar. | |||
4 IAPPLICABILITY: ~ | |||
t N [_ | |||
m-...~- - ~ | |||
N . - - 5. ', . "'. h..m k .. | |||
At all times when there is fuelin the reactor control rod drivc mcchanic vesse damagc hc not bcci rulcd out. | |||
ACTIONS:\ %. | |||
-.[Thc--._ illanccj survc_0. | |||
tl A. LCO 3 3.A.1 cannot be met, | |||
.As 1 Be in HOT SHUTDOWN x within 12 hours o :. .= n177 x - | |||
Amendment NO-44 3/4.3 1 | |||
1' ATTACHMENT B LIMITING CONDITIONS FOR OPERATIOE SpRVEILLANCE RE9UIREMENTS 3.3 REACTIVITY CONTROL (Cont) 4.3 REACTIVITY CONTROL (Cont) n _ .m , | |||
.,.t1..m_ : . . _ _ i n _ _ t, . ' . n__: | |||
m.m i. ..m. z . .. m, s_m, , 2 r . . .. , 1_: . - | |||
.- - m. | |||
>s-..ti n. . . | |||
I | |||
.mi i | |||
i .___,[1 _1 , | |||
.l'.~ | |||
_J _,3.I._s_ m_ .I m m u -_i -. .J ..: . ,.A. | |||
r.t . . . . . ~ .mm m v.~. l f. ~_s._ma . _ _ . | |||
j | |||
. m s. - . w . m s. s -.m. u. | |||
s.-....m m | |||
: m. .m.._.,. .. r _ ._ .I .~ym. | |||
_ . _ _ _ m. u,1. s_ .u.-._ . . _., 1 .c . u ,_ | |||
..._u.._ | |||
..-m m | |||
_r .f_._._t,_ -.s | |||
, _..A_ | |||
.u..,1.,. u_ . ~, y m . | |||
.a.....__.A. _a... u_.,. | |||
: s. v . ....m. | |||
m | |||
.-mm m. | |||
u___ _a.._a _ u_. | |||
. ~ m. m. m- m. mm. - m s. . ._sm . _ . . . . s..~.. | |||
w g. _, __ _: __, , | |||
m.-. .-...,..... | |||
.u.~_ | |||
m | |||
_m __, | |||
-...m. | |||
.u___ | |||
: s. .m _.~ | |||
m..a ., | |||
: 1. 1. | |||
s u__ | |||
~m u__ | |||
LCO S.3At -t _a._., | |||
.. u ,, | |||
m.... | |||
u_ | |||
ms .._ _....u m ym m .1 m.m.. | |||
,a._.~..,s__; -u.__. | |||
_ _ _ _ - - . . - . . _ , _ .. a | |||
: m. .m.m. .mm | |||
.s.. | |||
u _mm, , , , , | |||
c _ _ _1 ., 1s._ _ 1. w _m . ... . ...m 2_ | |||
___u.~__..._,_ __,,_. | |||
mys.m.. . 1. m_ . .s. .~ . , -..m,_ u. ~, eettty c_: , . . - _ 1_ c M, 2. . '"__--"..*_,_''''_~.m'__",''~__;"' | |||
u, . m | |||
~- | |||
, 2. .m ~ . -...m. .-m. | |||
g er o s.~m. . _ ,. | |||
_a 2_r..__ .u._ | |||
.._-,_.m.u | |||
. -m m s.., | |||
.4..,. 2.___,_a _ 2 _ .._2__,s.. | |||
x dicar.cd chcIl not bc | |||
. ~m. ._m m.~ ..mm. .-..i SR 4 3 B.15 Determine the posPJon of each Control m y3 s | |||
.. Genest 4 ~ | |||
.1 . | |||
__.1a__ | |||
-.~~~.s.m a : | |||
. ~es . m m u | |||
___u, rod once per 24 hours. I | |||
: ACTION O ' | |||
y , ...,.. .m. , ._- x. - - . . | |||
. 1 | |||
: a. . , , _ .sm | |||
_ .u_. *. L..._ ____! - ._A ...~ "u .. SR 4 3 B 14 ' | |||
3_.._ s. m s. . m. m m.~m v s. . . . m s. - mr Venfy each control rod scrum time from fully M.4 c _ _ _1 e i , . m __ , , n , ___ , M'8 "r"_^'_'","'""..**',,''.'u"_".'_. | |||
u u withdrawn to notch E*sition 04 ls 5 7 seconds 1 ._~ y s_. ._ m m | |||
. n_ , um .. m. s., | |||
-..u_ .. | |||
~~ in accordance with SR 4 3 C.1 or SR 4.3 C.2. | |||
.__._s ___ _ , | |||
gp ~.- -.u m s.~...v. .-- | |||
A A m..1..- .- | |||
t.00 3.8.S.1 | |||
* e*-"*- '~i' -- - - -" --' | |||
- '~-' | |||
SR 4 3 B.1.3 N M'7 ACTION E dicarmed c1ec ricc1l'i . ' | |||
Verify each withdrawn control rod i does not go to the withdrawn iA7 - er n.._:__ | |||
- . . ..3 | |||
.m..~m. ym m m y s . _. 1_.., | |||
s.. | |||
overtravel position. | |||
1r ..._L. __ _c t u. ~_ ~ . mm s. . v. . _ _ _ ._eMe | |||
.f .~ys. | |||
F. Requked action ard | |||
_g | |||
_ m ._ | |||
,_m..,..3 .vm _ m,. _u..,,.. | |||
m | |||
.~m mm-m | |||
..___a c.___ | |||
completion tame of -# _m.v _ u... s. . m ys.~ .1c.,__m_.s. | |||
. 2v.. , , | |||
_ _ ., . s . e 4 condmon A, C, D or _.._u_ 1_. | |||
" ' ' " " '~ ' --. - "" "'' . . . _i, ."" ""' | |||
E. not met. B. Control Rode, ODerability (A2 | |||
% { | |||
__.a. | |||
m ,no,, +r +t-tHefh.- | |||
r- - - - s. | |||
. - - - --.~~ | |||
.._.,.._.._a m | |||
p* ** | |||
__._,1_ | |||
*~r | |||
..___..._m,, u_ | |||
control rode -.m u. . mu.___ .- | |||
s ., t, __ ____ | |||
m ~s -.m_,m. | |||
.. _ , ,,_ ,'"'_'J, | |||
***'-M'''J | |||
___u ..,ua_''""._* ' * *^ > | |||
i inoperable. _a_ .1u -- - - ~ - -- - - - ~ ~ ' "" | |||
-_ -.m _~-.m. | |||
~ . . . . _ . _ . _.m.. | |||
. _ _____ _ _ , . _, _ _ m,,__. | |||
t | |||
_.._I_.. f_.. 3- _ . . _ _ _ . . _f ""'''V*' 'V''"* "'"# *V^*V"# | |||
* 1 se in hot - ~ ' - --- -- s^-- j | |||
_._.a_"~_c__ | |||
i swToom | |||
.nn r"-- ." s'e Nn 12 hours. | |||
_.._.._13, | |||
+-'-s"'"~"- | |||
.2____. _c e7 m__ | |||
~' -'- | |||
-u_ _a | |||
-v" - .: m __.._ | |||
"*u~~""" | |||
_n__ :m .. _ , ..,.o. , , | |||
_ ,__m _ . . _ | |||
+u~ --- - ci - | |||
r__ | |||
~ ~- ~w .m_.e l | |||
, s. .- m . ~ s-Ms ___m _, | |||
.w.._,m,.1_ .'. yv mmuw _ __ | |||
. y1.- pcr ,,-dayer l | |||
: r. m. . | |||
mm. ._,_,.s__~_.._, | |||
~ . . . . | |||
_m__.._ | |||
--s.. | |||
v. | |||
B. | |||
'A- 22_____ru,_ _ _ _ _ _ . _ _ ., .u Cont rol Rodh Operabili tv. l -2 "+"--"-~*- | |||
- ~ r v"- | |||
.mmm.mm~m,. | |||
v+ | |||
1_.. | |||
~~ | |||
.m.. . v. . | |||
4v "ac'. control rod chcIl bc D 'C"Cr* UT 1010101 20d3 | |||
-y.- | |||
,.a | |||
>_2.._ | |||
m ... .. | |||
.L' 4 #~ " ~- r - - - --~~- | |||
dicccrnibic, Cubac scnt | |||
%nW completely ;r'crted and thc Control rod direct ioncE-of en. .--*"'"U | |||
_ _ _1 _ 2 _ | |||
_c .u_ | |||
_a_ | |||
.u control /cl^.c3 dicar .cd e.cm.._ mm | |||
.mmm. | |||
1_ | |||
m | |||
.a. s. ,. s. .__m_1_,,.,.. .. gm . y. . . m ~ . m | |||
____m m . 2,_ ,.. . _ _u.~.. , , | |||
u.__ y . .c , .____a. | |||
,~, | |||
.u__ .._ .: | |||
mvm, | |||
~m m yy . .,. | |||
z_ | |||
.u_ | |||
s.~ __t..,_, | |||
. s. m .. . | |||
. , , , .. ..r,.. 2_._.,___.._._ | |||
mm. mmm .v.. | |||
sv.~r i | |||
__a :__ .. u _ | |||
..u._. . w w w i v .- .' o rc;P;n3C- | |||
. . . .~ s..~ | |||
M7 i | |||
.__,.._2 , . . _ ___. __, ._ 2 .a v | |||
.s.. . - , -m.m. -m m:. . ..-. _ _ l | |||
. ~_ _ . , .m u ,_ ___.._a N , | |||
I r___ ,,_m .~~.s.",- -"s - | |||
: a. Each tirne the control rod is withdrawn to "fud out" +- -- - I my_.-~ | |||
__.~m . | |||
pom on. | |||
j f-AND b Pnor to dectanng control rod OPERABLE after , | |||
Ls I. work on control rod or CRD system that could om:,.w 477 affect coupl.ng. 4 m . - .. | |||
/ 1 Amendment NoA4424 3/4.3-2 | |||
n ATTACHMENT B kIMITING CONDITIONS FoR OPERATION SyRVEILI.ANCE REoUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REACTIVITY CONTROL A.2 B. | |||
Control Rods' (C^^t) OPERABILITY _ B. Control Rod; (Cent)OPERABILITYj _ | |||
LCO 3 3 8 2 & The' control rod drive housTn'g qsup~ port sy< stem shall be in pla]c.e:- | |||
. k | |||
*i t.^. ten the red 20 r"t5dr r;- the " ret time, | |||
: f. *e . 4 ~__ _- s - - . | |||
jd.unng reactor powerapeation and' r : ;uent te e:L L.' | |||
APPUCABluTY: when the reactor coolant system is -a ^ or-afted g,refur!!n"g^ut-^;Ete^1e~that pressunzed above atmospheric .0'ntenen - p pressure with fuelin the reactor tEd''J-M: not go to the, elm _s e_.l ,'"..^.__' _. -- -". ~~. .'.. .U. . ^_ d _ ,_.- ~ _ . | |||
^. .". -. ~ . . " ... " .r^ ' ~ ~ * - ^ ^ - | |||
J' 1 rl. a.it.h,, | |||
. . . In a,. a_ A,em.A. C r------ mneine a.im.- n ~ | |||
Ag' Af 1 QQA....41. . . . . . . | |||
AM6sg K f~ d. ] The control rod drive housing (b43 B] support system shall be A. LCO 3 3 B 2 cannot be met. | |||
: in COLD SHUTDOWN inspected after reassembly and twi 24 hours. / the results of the inspection I recorded. | |||
& a: No contre! r^de the!! ba acred fM._4 3 F i Perform an INSTRUEIENT | |||
- FUNCT1oNKL TEs u..,w. .a_n,6.s. .n,. .,a_a_n.m_ _ _ . , l..e. u_ _ l.m_ u. .s _O n. 0,L,, | |||
d' L_Qr]- Pnor to control rod withdrawal for | |||
._ . a_ nm. ...., o_ _m ,. _ m. . m c . . . _ r . .- startup or insertior. to reduce . | |||
wm.a_ m_ m. .m .u.. , _ _.,, _m_ , m_ ,. u - ,. | |||
. . _ ., . . . - - _ power below 20%,of-the i | |||
.wn. | |||
. . . .o.. ma_ \.A./m.., . . w L.Ainim..l.,a., /.o t.A A.,i | |||
. s .. | |||
we_ r. _a w n.; A.,, m.f....h.. | |||
I, mm., akin A' m e wima am mi .um i D. M_ i.A.fM.. .s. , 4 _ | |||
g.. ..r-'---' ' ' - " ' ' " ' ' ' ' - ' - - - - gg;,;,n;,,, f o. ,tg A ---f-.--. | |||
I-.--...-- m a i e x aH. u.-. | |||
: gao3A.s . , m a , | |||
. - - . .n.. m,. w . . m..m.m-ma ut,uu. emot Im, ,: w ,, , | |||
a ,. --. . .- - m u,, .u o s A = A I,. | |||
t . . x. . . a_ | |||
___.,.'r----'"'"''' " ' - - ' " " | |||
r,mm.,.wim i, on m u, 'ma,. m.x,.a.,,..u Q, .: r--- "" " '''' "--- ,_ "'",'''u-''"'"" ,.m,m ,.,m,,- - - - - ' - " ', , , | |||
....m. .u' ,."m m 1,'.s n m_. u .'u'" .a ,','a.u, | |||
-r'''--"'''"'"' ' " ' " " I' m, .m | |||
,.,..-.'.r---'"='"''--'" | |||
.'...' ,'. .m. m.a.. m .,m.i. | |||
. _ . - . . ,.mn. | |||
a.w m.a. ax.m. m. -. . ._ ,.. .._ ,.. i ., nm. .,, .u o s A = A e n, a, 7 ne_ _e_ s_ . a,a. -. a $..s-.aU.,m .In. ,_..._ Amena_. . ,.m,y.n1 n.n, | |||
"''r---'* | |||
g I.'.%m.n.,m.l | |||
. . . . .. ,m.a ,n.a.. m.en.e... .a.n.a. .wn | |||
_,,,,,,,;,,,,,w, n, , r---~ . "- - | |||
. ._,.m.,,.., - . . - . . m. .a.u. . m. | |||
. . _.. i. m, . | |||
in. ._. .. i.m.,.,. w en.. u_ ._ ., wit._ws G0mfW , - - - - - - - - - | |||
.---m, s e.s . . A'8~ 1 | |||
. mssmi,,,, .u e., | |||
, heen 71 G- -'"i=---'-'---- | |||
,, m ,,, ,, . i m,, | |||
/ Leo 4.8.MJ, | |||
-e m.m,u. ._ ,, , e.u. .___.m. .-.-,. | |||
. _n_ , .n. ,, . ,. n Of the te!::t!^n e~owof-at | |||
,,,,,,,,m,,,,,,,,,,,,,,,,,,,, | |||
.am.Awl | |||
. _ a. e_ m. .,_ Sn.0,L. a_n, Inn. me. * *- - - - - | |||
"''"7"" | |||
__... r----- m . m t ,'"m a1,,' m e ,s a ," g'' " | |||
M, .- * ".. m.....A..'.'..m..m..+.h.^.8._-..", | |||
-ogan''',',',',,,,','--''"- | |||
in. .e. m.a,._mn. | |||
- -. ..m. enne.m.s. ,m.a n uA. .ig | |||
'"""s'-r-I, | |||
.. . . _ . a n.m.. _ f_a.ri.N.,. | |||
. m H..,s _._ | |||
, ale ._a,m. . .m.a I..e t.oe , | |||
-__ .. . .k, .n. n. . n. 4. n. a_m_i.._e . . b 4._. | |||
"ad8", ;a.a *ha | |||
-- - ----- ed ht^^L. | |||
fun"*!On of 2n ^> 't Of | |||
& .e.n.a m. u. ..n. . .u. | |||
. ,. m..-,.._m_ | |||
.. .___ _ , i .,. o u_ _ m. ,,. | |||
,mmoonm ,mnemt ma m,wi, w | |||
- - " ~ ' " " ' ' ' ~ ' " " " " " ' | |||
_on.a,t.-___... a,, tan. n,. . . . eu r-- - ''- le " A*Ad a" > s a^ m^= +h i - | |||
,n. . .o_mi ... . im. m. .m.,. s. a.s. o. n.u, -. . emn.e.m. .wm.,m.,u,""'"-"'"'"" | |||
k N ,,,, | |||
,#.,M , .R n.#.!1_. _. _ . _. ..,. M | |||
. _ .kk#h | |||
. _ . .A- ,M 8,# $. #.,,..G | |||
,h _. | |||
.e .in.n.i | |||
-r---- | |||
mm. .. , m,m, I, tm , | |||
f SR 4 3 F.2 N -m | |||
%haR 0 020 d^!*.2 '. Venfy the RM automebc bypass setpoint Me i to be > 20% RTP every 24 rnonths. | |||
%_ s s | |||
SR 4 3 F 3 N Venfying control rod sequences input to the RM are d g conformance with BPWs prior to dectanng RM o.m.a. :mn, .on.Q. | |||
OPERABLE following loading of sequence into RVWI. | |||
Amendment No. 39, 478 3/4.3-3 | |||
ATTACHMENT B LIMITING FONDITIONS FOR OPERATRON SURVEXLLANCE REQUXREMENTS 3.3 REACTIVITY CONTPOL (Cont) 4.3 PEACTIVITY CONTROL (Cont) A,i , | |||
F A2L M B. Control Rod B. | |||
' cont ) OPERABILITY] ControlRodd(Cont) OPERABILITY l h~o33ph>] l Control rods shall not be 9 g[M Prior to control rod withdrawal withdrawn for startuplee l 'cr duringi J lrefEcTf Tiinless at least two (# 3 for startupherIfy~thIt lrcfucling, at least A, source range channels have an , | |||
two sour 8e range channels have observed count rate equal to or An' an observed count rate of at greater than three counts per least three counts per second. | |||
second. $ m m hy j Gr Thc 'TJi chall bc cpcrcbic cc 19'*"*G **'d' ' '"d' ' ' ' | |||
g_ rcquired F Tabic 3.2.C 1, or MTKWS-M. | |||
centrol rod w;thdrcuci c';11 bC y A. LCO 3.3 8.3 carmot te met. | |||
L 1 . _ L. - | |||
""'"'~2 ' | |||
~ % | |||
1 Pleon the mode snach m shutdown- hwnedutk C. | |||
Scram Insertion Times C. Scram Insertion Times l I | |||
3 C )l. Average scram insertion time, for all operable control rods - | |||
>] | |||
~s Following each refueling outage, or after a reactor As from de-energization of the Ed3Cj shutdown that is greater than scram pilot valve solenoids to 120 days, each operable control dropout (DO) of notches 04, rod shall be subjected to scram As-24, 34, and 44 shall be no time tests from the fully greater than: withdrawn position. If testing Notch Average Scram is not accomplished with the i l' | |||
Position Times (seconds) nuclear system pressure above 950 psig, the measured scram 44 DO 0.508 insertion time shall be 34 DO 1.252 extrapolated to reactor 24 DO 2.016 pressures above 950 psig using 04 DO 3.578 previously determined correlations. Testing of all operable control rods shall be completed prior to exceeding 40% rated thermal power. | |||
1 i | |||
i l | |||
l | |||
''Ci!r 1 ** | |||
Amendment No.15, SS,124,139,165 3/4.3-4 | |||
ATTACHMENT B LJMITING CONDITIONS FOR OPERATIQN SERVERLLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REAR'TIVITY CONTROL C. Scram Insert ion Times (Cont) C. S_ cram Insertion Times | |||
: 2. Average scram insertion time - Within each 120 days of for the three fastest operable -k>W b operation, a minimum of 10% of control rods in each group of IR43C2) | |||
'S | |||
~ ; the control rod drives, on a four control rods in all two- rotating basis, shall be scram by-two arrays from de- g tested as in,4.3.C.1. An energization of the scram evaluation shall be completed pilot valve solenoids to every 120 days of operation to dropout (DO) of notches 04, provide reasonable assurance 24, 34, and 44 shall be no As that proper performance is greater than: being maintained. | |||
Notch Average Scram Position Times (seconds) 44 DO 0.538 i 34 DO 1.327 24 DO 2.137 04 DO 3.793 A' 4 | |||
D. ontrol Rod Accumulators | |||
+r T': manimur arrar .na c r t ior. -v time for any operabic control Q4 3 D Once a shift, check the status of red frcr de encrg:rctic- of K the pressure and level alarms for the scram pilot ecl ec each accumulator. | |||
b.. ncicac d to drorcut of " cts 0; ch^11 ;ct cncccd '.00 j | |||
ccccada, i APPLCABIL TY: 8 D. Control Rod Accumulators RUN and STARTUP MoOES; . | |||
REFUEL MODE uuhon the reactor vessel head h itAy 1.t cli rccctor cpcrc:ieg en==ned. -- -- | |||
4 prcscurcs, a red accumulater mcy - - | |||
I u_ | |||
2.-__.__u.s._ c . . . 2 _2.._u._, | |||
-- ACTONS: Mg - 9 | |||
.~ | |||
.~r... s. .~ | |||
cther control red . thc mine rod | |||
( Leo a s e cennoi to n i x , | |||
aquarc array Orctnd this rod haa \1 Be in hot SHUTDOWN ewhm 12 hours. ) | |||
e., N l w -Incpc rcbic accumulet-ee- j Er Dircctionci contrci eclec 4 Msart s ~ cicctrically dicarmcd ubilc in i LCO 3.3.D | |||
_, c :- fully incerted pca tion h Ccrcr inscrtion tinc grcatcr l than thr. monimum permincibic 1 | |||
Ao i 4ascrtics,tima l | |||
) | |||
If a contrc1 red ustS on ! | |||
.nopcrab1 accumulator is inscrted " full in" and :ta cirectic:.cl contrci calecs arc ! | |||
clectrically dicarmcd, it shal , | |||
act be considcrcd to hacc cn l n o p c r c b i c a c::u m u l a t e r I | |||
l t | |||
Revicion 186 Amendment No.-65,124,146A65 3/4.3-5 | |||
ATTACHMENT B LIMITING CONDITIONS FOR OPERATION SURVEIL 7.ANCE REQU3REMENTS 3.3 PEACTIVITY CONTROL (Cont) 4.3 PEACTIVITY CONTROL (Cont) | |||
A E. Reactivity Anomalles E. Reactivity Anomalles .. | |||
A,3 QCO3 ihe reactivity equivalent of g During [the atcrtup tcai progrc= l 4 the difference between the V lendjstartups fo71owlWg j Q actual critical rod | |||
'4* | |||
refueling outages, the critical ' | |||
m configuration and the expected - | |||
rod configurations will be Am osmy configuratiorfduring poucr ] compared to the expected i QN 4cperaticg 5hh11 yot exceed 1F configurations at selected ) | |||
Gk7 Lp Y H M I=IT-~I;cuccc5@ operating conditions. These ccncws ~th rcactor will be chut down comparisons will be used as a tu ,% | |||
' until the causc Saa beer base data for reactivity I g , ,, , +dctcr-incd and cor ccti te monitoring during subsequent SHutDom j sccicnc havc bcc;. tchcr if such power operation throughout the ) | |||
E I~cct icr 7 crc appropriate,- | |||
fuel cycle. At specific power operating conditions, the 40 h -Ef Opccificat ion; 2. 2. " t.'rcugh critical rod configuration will 0 abovc caract bc ct, an be compared to the ordcrly rhutdcun shall bc configuration expected based 4e h4eted and the rccctor chc11 upon appropriately corrected bc i- the ccid Chutdcun past data. This comparison condition withir '' Scura, will be made at least every Ah'' a Cpecification; 2.2.A through D full power month. | |||
Ch'vc do not opply uhcr. thcr; j is ,c tuc1 1: the rcactor h ::ct I vcuccl. | |||
Occd] !A} | |||
G. Scram Discharce Volume G. Scram Discharae Volume _ | |||
gN 3 Scram d'ischarge volume | |||
*~ | |||
'he scram discharge volume drain and vent valves; y | |||
h'As ]0330)*operableNch5cr ] | |||
drain & vent valves shall be m5WL50.". Q3 0.9 p e r i | |||
Verif M open at least | |||
* c rod i; - | |||
once per month. | |||
V(0fi'~cp5cabiccontrol w;thdrawr - | |||
Testdas specified in Aa _ [ 43G2 h b l | |||
o M--any e f--t-he scram d.13. These valves may discharge volume drain or .. 4 be closed intermittently (ACTION A-~\ ' A is; ' | |||
vent valves er-e made or for testing under foundinoperable[.i.cr35iIy administrative control. | |||
3?i5IT~bc >:itictcd y[0h&E5a ; | |||
jai r-i the rccctor shali | |||
[Ee+d-{ Shut 3own wiElii~fbe in 24 A] During each refueling interval verify the scram SR 4 3-Gg hours. discharge volume drain and vent valves: | |||
HO 12 IA,A 2 -[ s | |||
: a. Close within 30 seconds after receipt of a N reactor scram signal end APPLICABILfTY RUN and STARTUP MoOE ^ | |||
REFUEL MOoE when the reactor b. Open when the seram is | |||
* h"*d W " 9 reset. | |||
A 9:&!cr in Amendment NO. 65, 4 49 3/4.3-6 | |||
- llH99ft tl BJ pontrol Rod Opirability . | |||
. Insoft 2. | |||
b ~ _ | |||
LCO 3 3 B 1 B Control Rod Oprability Each control rod chall be OPERABLE. | |||
* SR 4.3 B 1.1 6EPLICABILITY: | |||
RUN and STARTUP MODES; NOTE Not required to be performed until 7 days after REFUEL MODE when the reactor vessel the control rod is withdrawn and thermal power is head is fully tensioned. (See also 3.10.D-) greater than the LPSP of the RWM. | |||
ACTIONS' A. One withdrawn control rod stuck. Insert each fully withdrawn OPERABLE control rod at least one notch once per 7 days. | |||
NOTE Rod Worth Minimizer (RWM) may be SR 4 3 B.12 bypassed as allowed by LCO 3.3.F. | |||
NOTE 1 Venfy stuck control rod is Not required to be performed until 31 days after separated from other inoperable the control rod is withdrawn and thermal power is control rods by two or more greater than the LPSP of the RWM. | |||
OPERABLE control rods immediately. | |||
Insert each partially withdrawn OPERABLE lL[ ' | |||
AND control rod at least one notch once per 31 days. | |||
2 Disarm the associated control rod drive (CRD) within 2 hours. | |||
3 Perform SR 4.3.8.1.1 and SR 4.3.B.1.2 for each withdrawn OPERABLE control rod within 24 hours from discovery of Condition A concurrent with thermal power greater than the Low Power Setpoint(LPSP)of l | |||
the RWM. j AND 4 Venfy LCO 3.3.A.1 is met within 72 hours. | |||
AND | |||
! 5 NOTE Not applicable when thermal power > 20 % RTP, Ensure stuck control rod is in l compliance with BPWS sequence I within 8 hours. | |||
I Verify control rod drop accident ' | |||
limit of 280 cal /gm is not exceeded within 8 hours. | |||
B. Two or more withdrawn control rods stuck. | |||
1 Be in HOT SHUTDOWN within I 12 hours. | |||
. Isnemt 4I | |||
' ~ | |||
(-- | |||
C. | |||
p NOTE Separate condition entry is allowed for fD. NOTE each control rod. Not appicable when thermal power | |||
> 20% RTP, One or more control rods inoperable for reasons other than Condfbon A or 8. Two or more inoperable control rods not in | |||
: c. . | |||
compliance with banked position | |||
!.. n' | |||
-g withdrawal sequence (BPWS) and not Rod Worth Mi imizer (RWM) may be bypassed as allowed by LCO tro r 3.3.F. | |||
1 Restore compliance with BPWS Fully insert inoperable control rod '" " | |||
within 3 hours. O_B AND 2 Venfy control rod drop accident 2 Disarm the associated CRD within limit of 280 cal /gm is not exceeded 4 hours-wfthin 8 hours. | |||
O_R 3 Restore control rod (s) to OPERABLE status within 8 hours. i l | |||
I l | |||
linewe si i E. NOTE Not applicable when thermal power | |||
> 20% RTP. | |||
I One or more groups with four or more inoperable control rods. | |||
1 Restore control rod (s) to OPERABLE status within 8 hours. | |||
9 | |||
. Insert 7 ' | |||
IW$l | |||
~ | |||
H. Rod Pattern Control F. Rod Worth Minimizer (RWM) | |||
< LCO 3 3 H LCO 3 3 F IW All OPERABLE control rods shall comply with the The RWM shall be OPERABLE. requirements of the banked posibon withdrawal sequence (BPWS) | |||
APPLICABILITY: APPLICABILITY: | |||
RUN and STARTUP MODES with reactor RUN and STARTUP MODES with reactor thermal power s 20 % RTP. | |||
thermal power s 20 % RTP. | |||
ACTIONS: ACTIONS: | |||
N C' | |||
A RWM inoperable dunng reactor startup. | |||
A. One or more OPERABLE control rods not 1 immediately suspend control rod in compliance with BPWS. | |||
movement except by scram. | |||
g NOTE 2.1 Immediately venfy by Rod Worth Minimizer (RWM) may administrative methods that be bypassed as allowed by LCO startup with RWM inoperable has ' | |||
not been performed in the last - [ | |||
12 months. Move associated control rod (s) to correct postion within 8 hours. | |||
AND | |||
, j q 2.2 Venfy movement of control rods 2 Venfy control rod drop accident \ | |||
g is in compliance with banked limit of 280 cal /gm is not position withdrawal sequence exceeded within 8 hours. | |||
(BPWS) by a second licensed OR operator or other qualified member of the technical staff g | |||
\2 Declare associated control rod (s) noperable within 8 hours. | |||
during control rod movement. | |||
B Rod worth minimizer (RWM) inoperable B. Nine or more OPERABLE control rods not during reactor shutdown. in compliance with BPWS. | |||
1 Venfy movement of control rods 1 NOTE is in accordance with BPWS by a Rod Worth Minirnizer (RWM) may | |||
\ second licensed operator or other be bypassed as allowed by LCO qualrfied member of the technical 3.3.F. | |||
staff during control rod movement. Immediately suspend withdrawal of control rods. | |||
l AND 2 Place the reactor mode switch in the shutdown position within 1 hour. | |||
SR 4.3 H Verify all OPERABLE control rods comply with BPWS every 24 hours. | |||
I f. | |||
( | |||
. Insert 8 O. ControlRod Accumuletors LCO 3 3 0 l | |||
Each control rod scram occumuletor tha8 be D. Two or rnore control rod accurrotetors l | |||
OPERABLE. Inoperable, concurrent with lose of APPLICABILITY: | |||
) reactry steam dome pressure < 960 l | |||
' RUN and STARTUP MODES; pe% | |||
REFUEL MODE when the reactor veneel 1 Vertfy all control rode 1 assocented with inoperable , | |||
ACTIONS: accumulators are Mly NOTE s.,e,sie en e,,,y . a wed o, eacn inserted immediately. | |||
[ | |||
control rod scram accumulator. | |||
2 Declare the assocated f control rode inoperable A. Controlrod scram accumuletor(s) , | |||
,,, inoperable with reactor steam dorne | |||
' peseurs 2 960 % | |||
% E. Required achon and assocated 1.1 Venfy no adjacent complebon trne of C.1 or D.1 not met OPERABLE controlrod has an inoperable scram i NOTE accumulator witNn Not applicable if all 1 hour. Inoperable control rod g scram occumulators are 1.2 Verify no adjacent control associated with fully rod is electrically desarmed inserted control rode. | |||
In a non-Miy inserted poetion witNn 1 hour. Place the reactor mode 93 ewRch in the shutdown 2 Deciere the associated poeluon immedetely. | |||
control rod inoperable within 1 hour. | |||
1 B. Controlrod scram accumulator (s) | |||
(noperable with reactor steam dome | |||
' pressure < 950 poig or reactor thermal power s 20 % RTP. | |||
1 Restore incporable accumulator to OPERABLE etetus within 8 hours. | |||
f 9B 2 Declare the sesociated control rod inoperable withm 8 hours. | |||
C. Two or more control rod accurnuistors inoperable, concurrent with loss of chargmg water pressure, when ruector steem dome preneure 2 960 poig. | |||
k 1 Restore chargmg water header pressure witNn 20 rmnutes M | |||
2 Restore inoperable accumulator (s) to OPERABLE etstus wthin 8 hours. | |||
5 | |||
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Attachment C Discussion of Changes | |||
1 1 | |||
DISCUSSION OF CHANGES ATTACHMENT C i Section 3/4.3 | |||
. REACTIVITY CONTROL ; | |||
ADMINISTRATIVE CHANGES ; | |||
. A, This change proposes to delete the generic Applicability and Objective sections of Current Technical Specifications (CTS) 3/4.3. The current wording does not provide any technical information (either actual or interpretational) necessary for plant operators, as well as other users, to understand or implement the requirements of the Technical Specifications. The generic Applicability will be replaced with specific APPLICABILITY for each Limiting Condition for Operation (LCO). Since this change will result in no technical changes (either actual or interpretational), it is considered administrative. | |||
A2 These changes propose editorial rewording (either adding or deleting) which result in no technical changes (either actual or interpretational) to the Technical Specifications. Therefore, they are considered administrative. | |||
As These proposed changes are considered human factor improvements to existing requirements as follows: | |||
(1) Each LCO will have its own unique alpha numeric identifier. | |||
(2) Each surveillance will have its own unique alpha numeric identifier. | |||
(3) Each LCO will have its own APPLICABILITY statement. l I | |||
(4) Each LCO will have all ACTIONS necessary to satisfy the LCO. ! | |||
These changes only affect the format in which the requirements are presented, not the technical content of the requirements. Since these changes will result in no technical changes (either actual or interpretational), they are considered administrative. | |||
A4 CTS 3.3.F states, " Specifications 3.3.A through D above do not apply when there is no fuel in the reactor vessel". This requirement is restated "At all times when there is fuel in the reactor vessel", as the APPLICABILITY for new LCO 3.3.A.1. | |||
In addition, CTS 3.3.F requires, "If Specification 3.3.A through D above cannot be met, an orderly shutdown will be initiated and the reactor shall be in Cold Shutdown condition within 24 hours". This requirement is restated as ACTIONS A. "LCO 3.3.B.2 cannot be met" and required ACTION A.1, "Be in COLD SHUTDOWN within 24 hours" for new LCO 3.3.B.2. | |||
As This proposed change will delete that portion of existing surveillance 4.3.A.2 that provides instructions for when the surveillance is not required. The requirements for when the surveillance is required are clear. It is understood that if the condition initially requiring the surveillance is no longer applicable, then the surveillance is not required. Therefore, this proposed change is considered administrative. | |||
3/4.3 DOC 1 | |||
l DISCUSSION OF CHANGES ATTACHMENT C Srction 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued) | |||
As This change proposes to replace CTS 3.3.A.2.b with proposed LCO 3.3.B.1, ACTIONS A.2 and C.2 and to delete that portion of CTS 3.3.A.2.b that provides details of the methods for disarming control rod drives (CRDs). The methods for disarming control rod drives (CRDs) are addressed in the current BASES and will be carried forward into the revised BASES. | |||
The requirement of CTS 3.3.A.2.b to disarm an inoperable control rod is retained in proposed LCO 3.3.B.1, ACTIONS A.2 and C.2. Also, CTS 3.3.A.2.b does not specify a time for completing this ACTION. Proposed ACTION A.2 will allow 2 hours to disarm an inoperable control rod that is stuck and ACTIONS C.1 and C.2 will allow 4 hours to insert and disarm all other inoperable control rods. | |||
These times recognize the actual operational steps involved to fully insert and/or disarm an inoperable conirol rod following discovery of the inoperable condition. | |||
Since the current requirements continue to be maintained, this change is considered administrative. | |||
The requirement of CTS 3.3.A.2.b to ensure Reactivity Margin (Specification 3.3.A.1) will be carried forward in proposed LCO 3.3.B.1, ACTION A.4 for a stuck control rod. For all other cases of inoperable control rods, proposed LCO 3.3 B.1 ACTIONS C.1 and C.2 will require them to be fully inserted and disarmed. | |||
This will ensure that the inoperable rod is in a position to satisfy reactivity margin. | |||
Since the current requirements will continue to be maintained, this change is considered administrative. | |||
A note is added (at the start of ACTIONS C), " Separate condition entry is allowed for each control rod", to provide direction consistent with the intent of the required ACTIONS for inoperable control rods. The required ACTIONS for each condition provide appropriate compensatory actions for each inoperable control rod. Complying with the required ACTIONS may allow for continued operation, and subsequent inoperable control rods are governed by subsequent condition entry and application of associated required ACTIONS. | |||
Required ACTION C.1 is modified by a note, which allows the RWM to be bypassed, if required, to allow insertion of the inoperable control rods and continued operation. LCO 3.3.F provides additional requirements when the RWM is bypassed to ensure compliance with the control rod drop accident (CRDA) analysis. | |||
The addition of these notes serve to assist the operator in complying with the required ACTIONS and do not alter the intent. Therefore, these proposed changes are considered administrative. | |||
3/4.3 DOC 2 L- . . | |||
__ __ l | |||
J DISCUSSION OF CHANGES ATTACHMENT C I Srction 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued) | |||
A7 CTS 3.3.A.2.e specifies that the number of inoperable control rods shall not exceea eight and that Specification 3.3 A.1 (Reactivity Margin - Core Loading) must be met at all times. The requirement to have no more than eight inoperable control rods is carried forward in proposed LCO 3.3.B.1, ACTION F. | |||
The requirement to ensure reactivity margin (CTS 3.3.A.1) will be carried forward in proposed LCO 3.3.B.1, ACTION A.4 for a stuck control rod. For all other cases of inoperable control rods, proposed LCO 3.3 B.1 ACTIONS C.1 and C.2 will require them to be fully inserted and disarmed, which will ensure that the inoperable rod is in a position to satisfy the reactivity margin. Since the current i requirements will continue to be maintained, this change is considered administrative. | |||
1 As CTS 3.3.B.1 requires each control rod to be coupled to its drive or completely inserted, and to electrically disarm the control rod directional control valves. The requirement that control rods be coupled to their drive mechanism is presented in proposed SR 4.3.B.1.3, making it a requirement for control rods to be considered OPERABLE. The actions to fully insert inoperable control rods and ) | |||
disarm them are presented in proposed LCO 3.3.B.1 ACTIONS C.1 and C.2. l Elimineting the existing specification for control rod coupling, by moving it to another specification (as a Surveillance Requirement), does not eliminate any requirements, or impose a new or different treatment of the requirements. l Therefore, this proposed change is considered administrative. ' | |||
; CTS 3.3.B.1 also exempts control rod coupling requirements when in the refuel condition with the reactor vented and allows two control rods to be removed as long as Specification 3.3.A.1 (Reactivity Margin) is met. CTS 3/4.10.D also specifies requirements for multiple control rod removal during core alterations (the refuel condition with the reactor vented). The requirements of 3/4.10.D also ensure that Reactivity Margin requirements are met. This proposed change will , | |||
delete the reference to when control rod coupling is not required and propose revising the APPLICABILITY for proposed LCO 3.3.B.1 to reference CTS LCO 3.10.D " Multiple Control Rod Removal". This proposed change does not eliminate any requirements or impose a new or different treatment of the requirements. Therefore, this proposed change is considered administrative. | |||
As CTS 3.3.B.2 exempts requirements for the control rod housing support system to be in place if all control rods are fully inserted and Specification 3.3.A.1 is met. | |||
This ACTION is being replaced with requirements to be in cold shutdown within 24 hours as described in Discussion of Changes A4 . This will ensure the requirement for all control rods to be inserted and Specification 3.3.A.1 are met. | |||
This proposed change does not eliminate any requirements or impose a new or different treatment of the requirements. Therefore, this proposed change is considered administrative. | |||
3/4.3 DOC 3 | |||
DISCUSSION OF CHANGES ATTACHMENT C S:ction 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued) | |||
Ao i CTS 4.3.B.3 requires the Rod Worth Minimizer (RWM) be verified OPERABLE prior to control rod withdrawal for startup or insertion to reduce power below 20% | |||
and specifies the details (a, b, c, and d) for performing this verification. | |||
Proposed SR 4.3 F.1 will require performance of an INSTRUMENT FUNCTIONAL TEST of the RWM prior to control rod withdrawal for startup or insertion to reduce power below 20%. The specific details, except for (a) verification of sequence input, for performing this test are relocated to the BASES. Since the original intent of the surveillance (i.e., to verify operability) is carried forward by requiring a functional test, this change is considered administrative. For discussion of change to CTS 4.3.B.3.a, verification of sequence input, see Discussion of Change L7. | |||
Asi CTS 3.3.B.4 and SR 4.3.B.5 specify the count rate requirements for the Source Range Monitors (SRMs) during refueling. CTS 3/4.10.B also specifies the operability requirements, including count rate for the SRMs during core alterations (refueling). The requirement to have greater than 3 counts per second is stated in both specifications. This proposed change will delete the reference to refueling in proposed LCO 3.3.B.3 and SR 4.3.B.3. Deleting the reference to refueling does not eliminate any requirements, or impose a new or different treatment of the requirements. Since the current requirements will continue to be maintained, this change is considered administrative. | |||
Au CTS 3.3.B.5 specifies the requirements for the Rod Block Monitor (RBM) as required by Table 3.2.C-1. CTS 3/4.2.C " Control Rod Block Actuation" also states the limiting conditions for operation for the instrumentation that initiates l control rod block are given in Table 3.2.C-1. Table 3.2.C-1 specifies the l APPLICABILITY for the RBM. The notes for Table 3.2.C-1 remain unchanged in the proposal and specifies the ACTIONS for an inoperable RBM. Table 4.2.C specifies the surveillance requirements for the RBM. This proposed change will l delete CTS 3.3.B.5. Deleting CTS 3.3.B.5 will eliminate confusion without eliminating any surveillance requirements, or imposing any new or different treatment of the requirements. Since the current requirements will continue to be maintained, this change is considered administrative. | |||
A 33 CTS 4.3.E still contains requirements for the startup test program. The startup test program was performed following initial fuel loading to demonstrate that the station was capable of operating safely and satisfactorily. This change deletes the reference to the startup test program which is no longer applicable. | |||
Au CTS 3.3.G.1 requires the scram discharge volume drain and vent valves to be OPERABLE whenever more than one OPERABLE control rod is withdrawn. | |||
Since the control rods can only be withdrawn in the RUN, STARTUP and i REFUEL MODES proposed LCO 3.3.G requires APPLICABILITY only in the RUN and STARTUP MODES, or REFUEL MODE when the reactor vessel head is fully tensioned. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling conditions. Since the requirements have not changed, this is considered an administrative change. | |||
3/4.3 DOC 4 | |||
l DISCUSSION OF CHANGES ATTACHMENT C j S::ction 3/4.3 REACTIVITY CONTROL l | |||
ADMINISTRATIVE CHANGES (continued) | |||
Asi CTS 4.3.G.1.b. specifies testing of the scram discharge volume vent and drain valves in accordance with CTS 3.13. The requirements for surveillance testing per the Inservice Test Program are contained in CTS 4.13. This change will provide the correct reference to the applicable CTS without eliminating any requirements, or imposing any new or different treatment of the requirements. | |||
Since the current requirements will continue to be maintained, this change is considered administrative. | |||
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l 3/4.3 DOC 5 | |||
DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE M, CTS 3.3.F allows a completion time of 24 hours to reach COLD SHUTDOWN if the CTS 3.3.A through D cannot be met. The following more restrictive requirements are proposed: | |||
Proposed LCO 3.3.B.1, required ACTIONS B.1 and F.1, reduces the completion time to 12 hours to reach HOT SHUTDOWN if the requirements for control rod operability cannot be met. This change is more restrictive because all rods must be fully inserted in 12 hours instead of the currently required 24 hours. | |||
Proposed LCO 3.3.B.3, required ACTION A.1, will require placing the mode switch in shutdown immediately if SRM count rate is < 3 counts /second prior to startup. This change is more restrictive because the mode switch must be placed in shutdown immediately instead of the currently required 24 hours. I LCO 3.3.C, required ACTION A.1, reduces the completion time to 12 hours to reach HOT SHUTDOWN if the requirements for control rod scram times cannot be met. This change is more restrictive because all I rods must be fully inserted in 12 hours instead of the currently required 24 hours. | |||
These proposed changes are more appropriate because once the control rods are fully inserted they have fulfilled their reactivity control requirements. Cooling I the unit down (proceeding from HOT SHUTDOWN to COLD SHUTDOWN) does j not provide any additional safety margin and, in some cases, could be counter i productive since positive reactivity is inserted during a cooldown. | |||
M2 This proposed change will delete the allowance to not consider control rods that are fully inserted and electrically disarmed inoperable (CTS 3.3.A.2.c). The control rod drop accident evaluation (NEDE-24011-P-A-11-US) assumes that the l | |||
plant is being operated within the constraints of the banked position withdrawal l sequence (BPWS). "NEDO-21231, Banked Position Withdrawal Sequence (BPWS)" requires all inoperable control rods capable of insertion to be fully inserted and disarmed when operating with reactor thermal power s; 20 % RTP. | |||
Proposed LCO 3.3.B.1, ACTION C, will require control rods capable of insertion (not stuck) to be fully inserted and disarmed once they have been declared inoperable regardless of reactor thermal power. Therefore, this is considered a more restrictive requirement. | |||
1 3/4.3 DOC 6 | |||
DISCUSSION OF CHANGES ATTACHMENT C Stction 3/4.3 REACTIVITY CONTROL i | |||
TECHNICAL CHANGES - MORE RESTRICTIVE (continued) | |||
M3 This proposed change will delete the requirements for control rod position indication from Tables 3.2.F and 4.2.F and add surveillance requirement SR 4.3.B.1.5. CTS Table 3.2.F requires control rod position indication to be OPERABLE and CTS Table 4.2.F requires an Instrument Check of the control rod position once per shift. CTS Actions for inoperable control rod position (Notes for Table 3.2.F) allow continued operation with no control rod position indication in the control room for 7 days before requiring a plant shutdown. | |||
Proposed SR 4.3.B.1.5 will require determination of control rod position only once per 24 hours which is less restrictive, however, if position indication is lost for a control rod then it must be considered inoperable, fully inserted, and disarmed. "NEDO-21231, Banked Pc "on Withdrawal Sequence (BPWS)" | |||
requires control rods to be fully insert o and disarmed when operating with reactor thermal power s 20 % RTP if tneir position can not be determined. | |||
Although control rod position may now be determined by the use of OPERABLE position indicators, by moving control rods to a position with an OPERABLE indicator, or by the use of other appropriate methods, if 9 or more control positions cannot be determined, the reactor must be brought to the HOT SHUTDOWN MODE. Therefore, this is considered a more restrictive requirement. j M4 Proposed LCO 3.3.B.1, ACTION D, addresses the condition when the reactor is s 20% Reactor Thermal Power (RTP) and two or more inoperable control rods are not in compliance with the Banked Position Withdrawal Sequence (BPWS), | |||
and are not separated by two or more OPERABLE control rods. The required ACTION is to restore compliance with the BPWS within 8 hours, verify control rod drop accident limit of 280 cal /gm is met within 8 hours, or restore the control rod to OPERABLE status within 8 hours. The control rod drop accident evaluation (NEDE-24011-P-A-11-US) assumes that the plant is being operated within the constraints of the banked position withdrawal sequence (BPWS). | |||
"NEDO-21231, Banked Position Withdrawal Sequence (BPWS)" requires all inoperable control rods be separated by two OPERABLE control rods when operating with reactor thermal power s 20 % RTP. Deviations from the BPWS may also be acceptable provided they do not create incremental rod worth which l would result in peak fuel enthalpy energies > 280 cel/gm. CTS does not stipulate any such restrictions. Therefore, this is considered a more restrictive change. | |||
A Note limits this requirement to 5 20% Rated Thermal Power (RTP) because analysis has shown that it is impossible to obtain a rod worth high enou0h to produce a peak fuel enthalpy of 280 cal /gm above 20 % RTP. | |||
3/4.3 DOC 7 | |||
DISCUSSION OF CHANGES ATTACHMENT C S:ction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) | |||
Ms ' CTS 3.3.A.2.d requires control rods be declared inoperable if they have scram taes greater than that permitted by CTS 3.3.C.3. The maximum insertion time requirement for control rods to be considered OPERABLE is moved to proposed Sit 4.3.B.1.4. If the requirements of the surveillance cannot be met, the control ro:1 is inoperable. Moving the requirement to another Specification (as a A rveillance Requirement) does not eliminate or impose a new or different tre atment of the requirements. | |||
CTS 3.3.A.2.d also allows a control rod with scram times greater than those permitted by CTS 3.3.C.3 (7 seconds) to remain at their current position and does not require them to be disarmed. This proposed change will require control rods with scram times greater than those permitted by CTS 3.3.C.3 be fully inserted and disarmed within 4 hours. Since this proposed change will not allow continued operation with control rods having scram times greater than 7 seconds, CTS 3.3.A.2.f is deleted. | |||
Me in addition to the limiting the total number of inoperable control rods, "NEDO. | |||
21231, Banked Position Withdrawal Sequence (BPWS)" also assumes that there are no more than three inoperable control rods in any one BPWS group. | |||
Proposed LCO 3.3.B.1, ACTION E, will ensure that this requirement is met. | |||
Since the BPWS is not required to be followed when thermal power is | |||
> 20% RTP, required ACTION E.1 is modified by a note indicating that the condition is not applicable > 20 % RTP. The allowed completion time of 8 hours considers the low probability of a CRDA occurring during this short period of time. The addition of a new requirement is a more restrictive change. | |||
M7 CTS SR 4.3.B.I.b requires that rod coupling be verified "when the rod is fully withdrawn the first time after each refueling outage." The proposed SR 4.3.B.1.3 j requires this coupling check each time the rod is fully withdrawn. Therefore, this 1 change is more restrictive. | |||
3/4.3 DOC 8 | |||
DISCUSSION OF CHANGES ATTACHMENT C Srction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGCS - MORE RESTRICTIVE (continued) | |||
Ms CTS 3.3.B.3.b requires control rod pattems and the sequence of withdrawal or insertion be established to ensure maximum rod worth is not exceeded. If the requirements of CTS '3.3.B.3 cannot be met, CTS 3.3.F requires an orderly shutdown be initiated and the plant brought to COLD SHUTDOWN within 24 hours. Under these conditions, the reactivity worth of an individual control rod could be in excess of that necessary to insert a peak enthalpy >280 cal / gram when the consequences of a control rod drop accident are most severe. | |||
Proposed LCO 3.3.H, " Rod Pattern Control'* will replace CTS 3.3.B.3.b with an appropriate LCO, APPLICABILITY, ACTIONS, and Surveillance Requirements ' | |||
that are consistent with the assumptions of NEDO 21231," Banked Position Withdrawal Sequence", Section 7.2, January 1977 PNPS is a BPWS plant as described in NEDE-24011-P-A, " General Electric btandard Application for Reactor Fuel", Section S.2.2.3.1. Compliance with BPWS, limits maximum rod worth such that fuel enthalpy addition due to CRDA will not exceed 280 cal /gm 4 fuel enthalpy. The proposed required ACTIONS will (A.1) ensure that out-of-sequence OPERABLE control rods are returned to their required positions within 8 hours, or (A.2) an analysis will be performed within 8 hours to ensure that the current positions do not create maximum incremental rod worth that would cause the CRDA limit of 280 cal /gm to be exceeded, or (A.3) the control rods will be declared inoperable within 8 hours. The 8 hour allowance is consistent with allowed actions described in NEDO-21231. The probability of a CRDA occurring during this short period is low, if a significant number of OPERABLE control rods (>8) are not in compliance with BPWS attempting to correct the out-of-sequence condition, especially if it requires withdrawing control rods, could worsen the situation. Therefore, actions are required to suspend control rod withdrawal immediately and place the mode switch in the shutdown position if the number of OPERABLE out-of-sequence control rods cannot be reduced to < 9 within 1 hour. CTS does not prescribe any completion times for determining and/or correcting out-of-sequence conditions. | |||
Therefore, the addition of required ACTIONS and completion times is considered a more restrictive change. ; | |||
I 3/4.3 DOC 9 l | |||
1 DISCUSSION OF CHANGES ATTACHMENT C Soction 3/4.3 F.EACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) | |||
Me This proposed change adds a new surveillance requirement (SR 4.3.F.2) for verifying that the RWM is not bypassed when reactor thermal power is s 20% | |||
every 24 months. The RWM is automatically bypassed when power is above a specified value. The power level is determined from feedwater flow and steam flow signals. The automatic bypass setpoint must be verified periodically to be | |||
> 20% RTP. The frequency takes into consideration the plant conditions required to perform the test and is intended to be consistent with a fuel cycle length of 24 months. | |||
Mw CTS 3.3.D allows an unspecified number of control rod accumulators to be inoperable as long as no other control rod in the nine-rod square array around this rod has a: (1) Inoperable accumulator, (2) directional control valve electrically disarmed while in a non-fully inserted position, or (3) scram insertion time creater than the maximum permissible insertion time. In addition, if the ! | |||
control rod is inserted " full-in" and its directional control valves are electrically disarmed, it need not be considered to have an inoperable accumulator and the l separation criteria would not have to be applied. l The proposed changes will impose more restrictive requirements as follows; l With reactor steam dome pressure :t 950 psig, proposed LCO 3.3.D, ACTION A will continGe to allow operation with multiple inoperable accumulators provided there are no adjacent OPERABLE control rods with inoperable accumulators (required ACTION A.1.1) and there are no adjacent control rods disarmed while in a non-fully inserted position (required ACTION A.1.2) or the control rod associated with the inoperable accumulator (s) must be declared inoperable (required ACTION A.2). Startup test results, as described in NEDO-20252, "STARTUP TEST RESULTS, PILGRIM NUCLEAR POWER STATION, UNIT 1", | |||
February 1974, show that the difference between the mean scram times for normal accumulator charging pressure with reactor pressure = 800 psig and accumulator pressure O psig with reactor pressure = 950 psig, was insignificant (0.04 sec on average) for the 4 slowest control rods. | |||
With reactor steam dome pressure < 950 psig or reactor thermal power s 20 % RTP, proposed LCO 3.3.D, ACTION B, will require control rods with | |||
-inoperable accumulators that cannot be restored to OPERABLE status within the specified time to be declared inoperable. With reactor steam dome pressure | |||
< 950 psig, the contribution to control rod scram time from the accumulator becomes more important. However, at any reactor pressure, the control rod will scram even without the associated accumulator, although probably not within the required scram times. Therefore, providing this short time (8 hours) to restore the accumulator to OPERABLE status does not significantly increase the risk of an ATWS event. | |||
l The CRDA evaluation (NEDE-24011-P-A-11-US) assumes that the plant is being operated within the constraints of the banked position withdrawal sequence (BPWS). "NEDO-21231, Banked Position Withdrawal 3/4.3 DOC 10 | |||
DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) | |||
Mw . Sequence (BPWS)" requires all inoperable accumulators to be restored to (continued) OPERABLE status within 8 hours or declare the associated control rod inoperable when operating with reactor thermal power s 20 % RTP. | |||
- Loss of charging water pressure could cause multiple accumulators to become inoperable resulting in severe degradation of scram performance. In addition, should the loss of charging water pressure be the result of a loss of control rod drive pump, the control rods can no longer be inserted with normal drive pressure and cooling water to the drives will be lost. Proposed ACTION C addresses the situation where multiple accumulators may be repidly becoming l inoperable due to loss of charging pressure when reactor pressure is 2 950 psig. | |||
Required ACTION C.1 addresses the need to restore charging water as soon as possible (within 20 minutes). If restoration of charging water pressure does not restore the accumulators to OPERABLE status, required ACTION C.2 provides additional time (8 hours) to restore the accumulators to OPERABLE status. This allowance provides a reasonable time to attempt investigation and restoration of the inoperable accumulators considering that reactor pressure is adequate to ensure the scram function of the control rods with inoperable accumulators. | |||
Proposed ACTION D addresses the situation where additional accumulators may be rapidly becoming inoperable due to a loss of charging pressure and allows any number of accumulators to be inoperable for up to 1 hour when reactor pressure is < 950 psig provided the associated control rods are verified to be fully inserted immediately. Provided all control rods with inoperable accumulators are fully inserted, this 1 hour allowance provides a reasonable time to attempt investigation and restoration of the inoperable accumulators. | |||
Proposed ACTION E ensures the reactor is returned to a condition in which the LCO does not apply when required actions to restore accumulator operability is not successful. If adequate charging pressure can not be restored within 20 minutes when reactor pressure is 2 950 psig, or all control rods with inoperable accumulators are not fully inserted when reactor pressure is < 950 psig, an immediate scram is required. This ensures that the extensions of ACTION C and D will not be used unless adequate CRD pressure is available to scram the reactor. | |||
A proposed Note at the beginning of the ACTIONS (" Separate Condition entry is allowed for each control rod scram accumulator") provides more explicit instructions for proper application of the new ACTIONS for Technical Specification compliance. Upon discovery of an inoperable accumulator, it is intended that each specific ACTION be applied regardless of its having been applied previously for other inoperable accumulators. This note is provided since more than one accumulator is allowed to be inoperable without requiring an immediate declaration of control rod inoperability. | |||
3/4.3 DOC 11 | |||
l DISCUSSION OF CHANGES ATTACHMENT C Soction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) | |||
M ii CTS 3.; E requires the reactor to be shut down if the reactrvity anomaly limit is ) | |||
exceedeu without specifying a completion time. Proposed LCO 3.3.E required ) | |||
ACTION A.1 will specify a completion time of 12 hours to reach HOT ' | |||
SHUTDOWN. | |||
This change is more restrictive because all rods must be fully inserted in 12 hours instead of the currently assumed 24 hours. | |||
M 12 CTS 3.3.G requires the reactor to be in COLD SHUTDOWN within 24 hours if any of the scram discharge volume drain or vent valves are made or found inoperable. Proposed LCO 3.3.G required ACTION A.1 reduces the completion time to 12 hours to reach HOT SHUTDOWN. | |||
This change is more restrictive because all rods must be fully inserted in 12 hours instead of the currently required 24 hours. Cooling the unit down (proceeding from HOT SHUTDOWN to COLD SHUTDOWN) does not provide any additional margin and, in some cases, could be counter productive since positive reactivity is inserted during a cooldown. | |||
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t 3/4.3 DOC 12 l | |||
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DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - RELOCATIONS R, CTS 3.3.C.3 provides a discussion of how to determine maximum scram insertion time. This change proposes to relocate details of the methods for timing control rod drives (CRDs) to the BASES for SR 4.3.B.1.4. The requirement to verify scram time is incorporated into proposed SR 4.3.B.1.4, therefore, it does not eliminate any requirements, or impose a new or different treatment of the requirements. Changes to these details will be controlled as described in 5.5.6. Technical Specification (TS) Bases Control Program. | |||
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I 3/4.3 DOC 13 | |||
DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE Li CTS 3.3.A.2.a requires control rods that cannot be moved with control rod drive or scram pressure be considered inoperable and that the reactor be brought to a shutdown condition within 48 hours unless investigation demonstrates that the cause of the failure is not due to a failed control rod drive mechanism collet housing. This proposed change will allow continued operation with one withdrawn control rod that cannot be moved with control rod drive or scram pressure (stuck rod) regardless of the reason for it being stuck (proposed LCO 3.3.B.1, ACTIONS A). Therefore, this change is considered less restrictive. | |||
Continued operation with one stuck control rod is contingent upon (1) verification that the separation criteria is met (required ACTION A.1), (2) the stuck rod is disarmed (required ACTION A.2), (3) all OPERABLE control rods are exercised to ensure there are no other stuck rods (required ACTION A.3), and (4) | |||
Reactivity Margin requirements are satisfied (required ACTION A.4). When operating at s 20 % RTP, an additional requirement (A.5) to verify compliance with BPWS sequence or perform an analysis within 8 hours to ensure tid the current positions do not create maximum incremental rod worth that would cause the CRDA limit of 280 cal /gm to be exceeded is imposed. NEDO-21231, " Banked Position Withdrawal Sequence", Section 7.2, January 1977, does not permit operation within the BPWS range while a stuck control rod exists unless analysis exists to support such operation. | |||
The existing limitation of CTS 3.3.A.2.a for investigating the reason for the failure to insert (e.g., failed collet housing)is being omitted. The requirement to determine the stuck condition was not due to collet housing failure was added to the PNPS TS in Amendment 14, February 3,1976, because of circumferential cracks resulting from stress assisted intergranular corrosion occurring in the collet housings of drives at several plants. The purpose of this amendment was to ensure that the reactor would not be operated with a large number of control rods with failed collet housings. The proposed ACTIONS will only allow continued operation with one stuck control rod, provided that all withdrawn control rods are tested within 24 hours to confirm no additional stuck control rods exist. The failure of a single control rod to insert (scram) will not prevent the reactor from reaching a subcritical condition. | |||
A completion time of 72 hours is allowed for ensuring reactivity margin requirements are met. CTS does not specify a completion time which could be interpreted to be within 24 hours consistent with CTS 3.3.F. The 72 hour completion time is considered appropriate because of the actions necessary to perform the analysis, and even with one control rod stuck in a withdrawn position, the remaining OPERABLE control rods will scram and provide the required shutdown reactivity. | |||
3/4.3 DOC 14 | |||
DISCUSSION OF CHANGES ATTACHMENT C Ssetion 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE Li A completion time of 8 hours is allowed for ensuring compliance with BPWS (continued) sequence or perform a rod worth analysis when s 20 % RTP. The 8 hours completion time is considered appropriate because of the limited number of allowed out-of-sequence control rods, the low probability of a CRDA occurring during the time the control rods are out-of-sequence, and is consistent with other corrective actions required by NEDO-21231. | |||
A Note is added to ACTION "A" that allows for bypassing the RWM in order to , | |||
fulfill the required ACTIONS A.3 and A.5, provided the proper ACTIONS of j proposed LCO 3.3.F (RWM) are taken. This is a human factors consideration to j ensure clarity of the requirement and allowance. | |||
I L2 CTS 4.3.A.2 requires that all partially or fully withdrawn control rods be exercised ! | |||
at least once per week. This SR could be satisfied by control rod withdrawal. | |||
However, it is possible for a control rod binding mechanism to exist that only i prevents control rod insertion. In such a case, a withdrawal test will not detect ' | |||
the problem. Therefore, proposed SRs 4.3.B.1.1 and 4.3.B.1.2 require control rods be inserted in lieu of the CTS requirement for " exercising". Since the purpose of the test is to ensure scram insertion capability, restricting the test to only allow control rod insertion increases the sensitivity of this test for detecting a problem that impacts this capability. | |||
The proposed requirements SR 4.3.B.1.1 and SR 4.3.B.1.2 will differentiate between fully and partially withdrawn rods. Fully withdrawn rods will still be inserted one notch once per 7 days. However, partially withdrawn rods will be i inserted one notch once per 31 days. The rational for decreasing the frequency ) | |||
of exercising partially withdrawn rods from 7 to 31 days is that partially withdrawn control rods have a significantly greater impact on core flux distribution than do fully withdrawn control rods. Power reductions may be required each week to perform this test on the partially withdrawn control rods. This potential impact on plant capacity is deemed excessive given the following considerations: | |||
I | |||
: 1) At full power, a large percentage of control rods (typically 80-90%) are fully withdrawn and would continue to be exercised each week. This represents a significant sample size when looking for an unexpected random event. | |||
: 2) Operating experience has shown " stuck" control rods to be a rare event while operating. | |||
: 3) Partially withdrawn control rods are exercised during plant operations to maintain reactor power level. Should a stuck rod be discovered, all of the remaining control rods (even partially withdrawn) must be exercised within 24 hours (proposed LCO 3.3.B.1, ACTION A.3). | |||
3/4.3 DOC 15 | |||
DISCUSSION OF CHANGES ATTACHMENT C SG;ction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
L3 CTS 4.3.A.2 requires all OPERABLE control rods be exercised once every 24 hours if reactor operation continues with three or more inoperable control rods. | |||
The originalintent of this requirement was to ensure the reliability of the remaining OPERABLE control rods if power operations were to continue with three or more not fully inserted, inoperable control rods. If the inoperable control rods were fully inserted and disarmed, they would not be considered inoperable (CTS 3.3.A.2.c) and the increased surveillance frequency would not apply. | |||
The proposed requirement for control rods that are inoperable but not stuck (LCO 3.3.8.1, ACTION C) is to fully insert and disarm the inoperable rod (s). | |||
Since continued power operation with not-fully inserted, inoperable control rods will not be allowed, there will be no requirement to exercise the OPERABLE rods to verify their operability other than the scheduled surveillance requirements in proposed SR 4.3.B.1.1 and SR 4.3.B.1.2. | |||
CTS 4.3.A.2 also requires all OPERABLE co,1 trol rods be exercised once every 24 hours if reactor operation continues with a stuck control rod for which CRD mechanism failure has not been ruled out. For a stuck control rod, regardless of the reason, the proposed requirement will require all OPERABLE rods be inserted at least one notch within 24 hours. This will verify the stuck control rod is not caused by a generic failure that would interfere with scram capability. | |||
Thereafter, continued testing of control rods will be at the normal frequency. | |||
Operating experience has shown stuck control rods to be a rare event during power operations. | |||
L4 in addition to verifying that the drive does not go to overtravel, CTS 4.3.B.1 also requires observance of a discernible response of the nuclear instrumentation when a control rod is withdrawn the first time following a refueling outage or after maintenance has been conducted. An indication of a flux level change on nuclear instruments demonstrates control rod motion out does not demonstrate that a control rod is coupled as is the intent of existing requirement 4.3.B.I.a. | |||
Therefore, this requirement is deleted. | |||
L5 CTS 4.3.B.1 requires observation that the control rod does not go to the overtravel position after maintenance without specifying the type of maintenance. | |||
- The proposed SR 4.3.B.1.3 will only require observing the control rod does not go to the overtravel position after maintenance that could affect coupling integrity. Since the purpose of the surveillance is to determine that the control rod is coupled, restricting the performance to maintenance that could affect coupling integrity is appropriate. | |||
l 3/4.3 DOC 16 | |||
DISCUSSION OF CHANGES ATTACHMENT C Srction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
Le CTS 3.3.B.3.a does not allow control rods to be moved when the reactor is below 20% rated power, except to shutdown the reactor, unless the RWM is OPERABLE. A maximum of two rods may be moved below 20% design power when the RWM is inoperable if all other rods except those which cannot be moved with control rod drive pressure are fully inserted. | |||
Proposed LCO 3.3.F, " Rod Worth Minimizer", will continue to require operability of the RWM below 20% of design power, however, the requirements on control - | |||
rod movement are being relaxed. Proposed LCO 3.3.F, ACTION A, will still require suspension of control rod movement when the RWM is inoperable during startup unless withdrawal has not been performed with the RWM inoperable in the 12 months, and a second licensed operator or other qualified member of the technical staff verifies movement of control rods is in compliance with the banked position withdrawal sequence (BPWS). The RWM function assists and supplements the operator with an effective backup control rod monitoring routine that enforces adherence to established startup, shutdown, and low power level control rod procedures. Allowing a second licensed operator or other qualified member of the technical staff to verify the control rod movement is in compliance with BPWS which also provides effective control. Not allowing more than one startup per 12 months will ensure that the RWM is maintained OPERABLE. | |||
Although CTS 3.3.B.3.a allows control rod movement to shutdown the reactor without any constraints, proposed LCO 3.3.F. ACTION B, will also require a second licensed operator or other qualified member of the technical staff to verify movement of control rods is in compliance with BPWS. | |||
L7 CTS 4.3.B.3.a requires verifying the control rod withdrawal sequence input to the RWM computer prior to control rod withdrawal for startup and prior to insertion to reduce power below 20%. This verification is required for each plant startup and shutdown. Proposed SR 4.3.F.3 will require this verification only once following loading of the sequence into the RWM computer. | |||
The potential for error occurs when the sequence is initially loaded into the computer. Once the rod withdrawal sequence is verified, controls are in place to ensure that changes cannot be made without prior approval. Any change would require reverification. | |||
3/4.3 DOC 17 | |||
1 DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
La CTS 3.3.F states that " Specifications 3.3.A through D above do not apply when there is no fuel in the reactor vessel". This implies that Specifications A through D it ust be met during all MODES of operation when there is fuel in the reactor vessel. In the HOT SHUTDOWN and COLD SHUTDOWN MODES, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod OPERABILITY during these conditions. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling conditions. Therefore, proposed LCO 3.3.B.1 is revised to require APPLICABILITY only in the RUN and STARTUP MODES, or REFUEL MODE when the reactor vessel head is fully tensioned. Since control rod scram times and control rod scram accumulators are conditions for control rod operability, LCOs 3.3.C and 3.3.D are also revised accordingly. In addition, there are no design bases accidents (DBAs) or abnormal operational transients (AOTs) identified for conditions when one or less control rods are withdrawn that l require a scram. Because the proposed changes do not require APPLICABILITY in all MODES, they are less restrictive. | |||
Le CTS 3.3.E requires the reactivity equivalent of the difference between the actual critical rod configuration and the expected configuration during power operation not exceed 1%AK. CTS defines reactor power operation as any operation with the mode switch in the "STARTUP" or "RUN" position with the reactor critical and ! | |||
above 1% design power. The core reactivity anomaly surveillance must be performed under steady state power operations (no control rod movement or | |||
^ | |||
core flow changes in progress) because of the small (< 1%) changes being evaluated. This is best performed after the generator is synchronized to the grid which requires the mode switch to be in RUN. In the STARTUP MODE, thermal power is low enough (s 5% RTP) such that reactivity anomalies are unlikely to occur. Therefore, proposed LCO 3.3.E is revised to be applicable only in the RUN MODE. Since proposed LCO 3.3.E will no longer be applicable in the STARTUP MODE, this change is less restrictive. | |||
3/4.3 DOC 18 | |||
I 1 | |||
Attachment D No Significant Hazards Discussion l | |||
l l | |||
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NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL | |||
.The Code of Federal Regulations (10 CFR 50.91) requires licensees requesting an amendment to provide an analysis, using the standards in 10 CFR 50.92, that determines whether a significant hazards consideration exists. The following analysis is provided in accordarv6 with 10 CFR 50.91 and 10 CFR 50.92 for the proposed amendment. | |||
ADMINISTRATIVE CHANGES (Ai , A2, A3 ,4A , As, Ae, A7 , A.8, Ag, iA o,iiA , A 12,Ai3 | |||
, Ai4,and A s:i Labeled Discussion of Changes, CTS 3/4.3) | |||
These proposed changes involve reformatting, renumbering, human factors, and rewording of the Technical Specifications and Bases. These changes, since they do not involve technical changes to the Technical Specifications, are administrative. All of the administrative changes conta,ned in the Discussion of Changes for this LCO are addressed by this evaluation. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
The proposed changes involve reformatting, renumbering, and rewording of the existing Technical Specifications and Bases along with other changes to the Technical Specifications discussed above. The reformatting, renumbering, and rewording along with the other changes listed involves no technical changes to existing Technical Specifications. These changes do not involve any physical alteration of the plant (no new or different type of equipment will be installed), introduce any new tests, nor change methods governing normal plant operation. | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: | |||
These proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed nor is any equipment being removed) nor change methods governing normal plant operation. The proposed change will not impose any new or different requirements nor eliminate any existing requirements. | |||
l I | |||
3/4.3 - N.S.H.C. 1 1 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued) | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: , | |||
i These change are administrative in nature and will not involve any technical changes. | |||
These changes do not involve any physical alteration of the plant (no new or different type of equipment will be installed nor is any equipment being removed), introduce any i new tests, nor change methods governing normal plant operation. | |||
1 i | |||
3/4.3 - N.S.H.C. 2 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 l REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (M i , M 2, M 3, M 4, Ms, Me, M 7, Ma, Mg, Mi o, Mii , and M12; Labeled Discussion of Changes, STS 3/4.3) | |||
These changes incorporate more restrictive changes into the current Technical Specifications by either making current requirements more stringent or by adding new requirements which currently do not exist. All of the more restrictive changes contained in the Discussion of Changes for this LCO are addressed by this evaluation. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
The proposed changes provide more stringent requirements than those currently in the Technical Specifications. The more restrictive requirements will not alter the operation of process variables, structures, systems, or components as described in the safety analyses; therefore, they will not involve a significant increase in the probability of an accident occurring. | |||
The proposed changes will ensure compliance with, "NEDO-21231, Banked Position Withdrawal Sequence (BPWS)" which limits maximum rod worth such that fuel enthalpy addition due to a control rod drop accident (CRDA) will not exceed 280 cal /gm fuel enthalpy or require the plant be placed in a condition where the LCOs do not apply sooner. - In addition, changes are proposed to require entering a MODE in which the LCOs do not apply sooner than currently required. Therefore, the new requirements may decrease the consequences of an analyzed event. | |||
: 2. Does the change create the possibility of a new or different kind of accident from any ] | |||
accident previously evaluated? ! | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated l because of the following: | |||
These more restrictive and new requirements will not alter the plant configuration (no new or different type of equipment will be installed nor is any equipment being removed) or change methods goveming normal plant operation. The changes do impose different requirements; however, they are consistent with assumptions made in the safety analyses. | |||
2/4.3 - N.S.H.C. 3 | |||
I-NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: I l | |||
I Adding these new requirements and making existing ones more restrictive does not involve a physical alteration of the plant (no new or different type of equipment will be installed nor is any equipment being removed), introduce any new tests, or change methods governing normal plant operation. The proposed changes will ensure I | |||
compliance with BPWS which limits maximum rod worth such that fuel enthalpy addition due to a CRDA will not exceed 280 cal /gm fuel enthalpy or require the plant be placed in a condition where the LCOs do not apply sooner or require entering a MODE in which the LCOs do not apply sooner than currently required. j i | |||
3/4.3 - N.S.H.C. 4 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - RELOCATIONS (Ri Labeled Discussion of Changes, CTS 3/4.3) | |||
This proposed change will relocate details of the methods for timing control rod drives (CRDs) to the BASES. | |||
BECo has evaluated this proposed Technical Specification change and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
This proposed change relocates details of the methods for timing control rod drives from the Technical Specifications to the BASES. The requirement to verify scram times is incorporated into proposed SR 3.3.B.1.4; therefore, it does not eliminate any requirements, or impose a new or different treatment of the requirements. The BASES are subject to the Technical Specifications (TS) Bases Control Program contained in the Administrative Controls Section of the Technical Specifications. Since any changes to the BASES will be in accordance with these requirements, no increase (significant or insignificant) in the probability or consequences of an accident previously evaluated will be allowed. | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: | |||
This change relocates details of the methods for timing control rod drives to the BASES. | |||
This change will not alter the plant configuration (no new or different type of equipment will be installed nor is any equipment being removed) or change methods governing normal plant operation. This change will not impose different requirements and adequate control of information will be maintained. This change will not alter assumptions made in the safety analysis and licensing basis. | |||
3/4.3 - N.S.H.C. 5 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - RELOCATIONS (continued) | |||
(R$Labeled Discussion of Changes, CTS 3/4.3) | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
This change relocates details of the methods for timing control rod drives not the requirement to ensure scram times are met. The requirement to verify scram times is incorporated into proposed SR 3.3.B.1.4, therefore, it does not eliminate any requirements, or impose a new or different treatment of the requirements. The requirements to be transposed from the Technical Specifications to the BASES are the same as the existing Technical Specifications. The BASES are subject to the Technical Specifications (TS) Bases Control Program contained in the Administrative Controls Section of the Technical Specifications. Since any changes to the BASES will be in accordance with these requirements, no increase (significant or insignificant) in the probability or consequences of an accident previously evaluated will be allowed. | |||
3/4.3 - N.S.H.C. 6 I | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE L,, Labeled Discussion of Changes for CTS 3/4.3 CTS 3.3.A.2.a requires control rods that cannot be moved with control rod drive or scram pressure be considered inoperable, and that the reactor be brought to a shutdown condition within 48 hours unless investigation demonstrates that the cause of the failure is not due to a failed control rod drive mechanism collet housing. This proposed change will allow continued operation with one withdrawn control rod that cannot be moved with control rod drive or scram pressure (stuck rod) regardless of the reason for it being stuck (proposed LCO 3.3.B.1, ACTIONS A).. Therefore, this change is considered less restrictive. | |||
Continued operation with one stuck control rod is contingent upon (1) verification that the separation criteria is met (required ACTION A.1), (2) the stuck rod is disarmed (required ACTION A.2), (3) all OPERABLE control rods are exercised to ensure there are no other stuck rods (required ACTION A.3), and (4) Reactivity Margin requirements are satisfied (required ACTION A.4). When operating at s 20 % RTP, an additional requirement (A.5) to verify compliance with BPWS sequence or perform an analysis within 8 hours to ensure that the current positions do not create maximum incremental rod worth that would cause the CRDA limit of 280 cal /gm to be exceeded is imposed. NEDO-21231, " Banked Position Withdrawal Sequence", Section 7.2, January 1977 does not permit operation within the BPWS range while a stuck control rod exists unless analysis exists to support such operation. | |||
The existing limitation of CTS 3.3.A.2.a for investigating the reason for the failure to insert (e.g., | |||
failed collet housing) is being omitted. The requirement to determine the stuck condition was not due to collet housing failure was added to the PNPS TS in Amendment 14, February 3, 1976 because of circumferential cracks resulting from stress assisted intergranular corrosion occurring in the collet housings of drives at several plants. The purpose of Amendment 14 was to ensure that the reactor would not be operated with a large number of control rods with failed collet housings. The proposed ACTIONS will only allow continued operation with one stuck control rod provided all withdrawn control rods are tested within 24 hours to confirm no additional stuck control rods exist. The failure of a single control rod to insert (scram) will not prevent the reactor from reaching a subcritical condition. | |||
A completion time of 72 hours is allowed for ensuring reactivity margin requirements are inet. | |||
CTS does not specify a completion time which could be interpreted to be within 24 hours ; | |||
consistent with CTS 3.3.F. The 72-hour completion time is considered appropriate because of j the ACTIONS necessary to perform the analysis and, even with one control rod stuck in a ! | |||
withdrawn position, the remaining OPERABLE control rods will scram and provide the required shutdown reactivity. | |||
A completion time of 8 hours is allowed for ensuring compliance with BPWS sequence or perform a rod worth analysis when s 20 % RTP. The 8-hour completion time is considered appropriate because of the limited number of allowed out-of-sequence control rods, the low probability of a CRDA occurring during the time the control rods are out-of-sequence, and is consistent with other corrective actions required by NEDO-21231. | |||
A note is added to ACTION "A" that allows for bypassing the RWM in order to fulfill the required ACTIONS A.3 and A.5, provided the proper ACTIONS of proposed LCO 3.3.F (Rod Worth Minimizer) are taken. This is a human factors consideration to ensure clarity of the requirement and allowance. j 3/4.3 - N.S.H.C. 7 j | |||
...l | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE Li , Labeled Discussion of Changes for CTS 3/4.3 (continued) | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? I Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
The probability of an accident previously evaluated is not increased because the proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. | |||
The consequences of an accident previously evaluated are not increased because the failure of a single control rod to insert will not prevent the reactor from reaching a subcritical condition as long as shutdown margin requirements are met. Elimination of the requirement to shutdown if one rod is stuck due to potential collet finger failure is being made concurrently with another change that will require a reactor shutdown if more than one rod is stuck for any reason. This additional restriction ensures that the reactor will be shut down as soon as it is determined that more than one rod may fail to scram. This differs from the existing requirement that allows operation with multiple stuck rods that are not fully inserted, provided reactivity margin is met. | |||
: 2. Does the change create the possibility of a new or different kind of accident from any , | |||
accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: | |||
This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The change does impose different requirements; however, the change is consistent with Shutdown Margin and CRDA assumptions made in the safety analysis. | |||
3/4.3 - N.S.H.C. 8 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL I | |||
i TECHNICAL CHANGES - LESS RESTRICTIVE LtLabeled Discussion of Changes for CTS 3/4.3 (continued) | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant ! | |||
reduction in a margin of safety because of the following: l Elimination of the requirement to shutdown if one rod is stuck due to potential collet , | |||
finger failure will not decrease a margin of safety because this change is being made I concurrently with another change that will require a reactor shutdown if more than one rod is stuck for any reason. This additional restriction ensures that the reactor will be shut down as soon as it is determined that more than one rod may fail to scram and the assumptions used in the analysis of those accidents and transient that depend on a scram may no longer be met. The failure of a single control rod to insert will not prevent the reactor from reaching a suberitical condition as long as shutdown margin requirements are met. | |||
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l 1 | |||
3/4.3 - N.S.H.C. 9 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
L2. Labeled Discussion of Changes for CTS 3/4.3 CTS 4.3.A.2 requires that all partially or fully withdrawn control rods be exercised at least once per week. This Surveillance Requirement (SR) could be satisfied by control rod withdrawal. | |||
However, it is possible for a control rod binding mechanism to exist that only prevents control rod insertion. In such a case, a withdrawal test will not detect the problem. Therefore, proposed SRs 4.3.B.1.1 and 4.3.B.1.2 require control rods to be inserted in lieu of the CTS requirement for " exercising". Since the purpose of the test is to ensure scram insertion capability, restricting the test to only allow control rod insertion increases the sensitivity of this test for detecting a problem that impacts this capability. | |||
The proposed requirements SR 4.3.B.1.1 and SR 4.3.B.1.2 will differentiate between fully and partially withdrawn rods. Fully withdrawn rods will still be inserted one notch once per 7 days. | |||
However, partially withdrawn rods will be inserted one notch once per 31 days. The rational for decreasing the frequency of exercising partially withdrawn rods from 7 to 31 days is that partially withdrawn control rods have a significantly greater affect on core flux distribution than do fully withdrawn control rods. Power reductions may be required each week to perform this test on the partially withdrawn control rods. This potential impact on plant capacity is deemed excessive given the following considerations: | |||
: 1) At full power a large percentage of control rods (typically 80-90%) are fully withdrawn and would continue to be exercised each week. This represents a significant sample size when looking for an unexpected random event. | |||
: 2) Operating experience has shown " stuck" control rods to be a rare event while operating. | |||
1 | |||
: 3) Partially withdrawn control rods are exercised during operations to maintain power level. Should a stuck rod be discovered, all of the remaining control rods (including those partially withdrawn) must be exercised within 24 hours (proposed LCO 3.3.B.1, ACTION A.3). | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
i The probability of an accident previously evaluated is not increased because the proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. | |||
3/4.3 - N.S.H.C. 10 | |||
_j | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (L2Labeled Comment / Discussion for CTS 3/4.3) (continued) | |||
The consequences of an accident previously evaluated are not significantly increased because the proposed change only increases the interval between performance of a surveillance for only 10% to 20% of the control rods (those that are partially withdrawn). | |||
The purpose of the surveillance is to verify that rods can be inserted, thus verifying that rods are not stuck and scram capability is maintained. The 80% to 90% of the control roda that are fully withdrawn will continue to be tested at the 7 day frequency and should a stuck control rod be found, all withdrawn control rods will have to be tested within 24 hours. In addition, this change is being implemented concurrently with more restrictive requirements goveming continued operation with stuck and inoperable control rods. | |||
Collectively, these changes provide assurance that when a scram is required, the assumptions used in the accident analysis (i.e., most reactive rod fully withdrawn does not scram) will be met. | |||
: 2. Does the change create the possibility of a new or different kind of accident from any I accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the I possibility of a new or different kind of accident from any accident previously evaluated ! | |||
because of the following: | |||
The proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, i modified, tested, or inspected. The proposed change increases the interval between 1 performance of surveillances designed to verify that rods can be inserted for only 10% | |||
to 20% of the control rods (those that are partially withdrawn) not the manner in which the curveillance is performed. | |||
: 3. Does this change involve a significant reduction in a margin cf safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
A margin of safety is not reduced even though the proposed increase in the interval between performances of a surveillance may increase the time before a stuck rod is discovered. However, the increased frequency does not apply to fully withdrawn rods I which represent a significant sample size (80% to 90%) when looking for an infrequent, random event. Additionally, this change is being implemented concurrently with more restrictive requirements goveming continued operation with stuck and inoperable control ! | |||
rods. Collectively, these changes provide assurance that when a scram is required, the assumptions used in the accident analysis (i.e., most reactive rod fully withdrawn does not scram) will be met. | |||
3/4.3 - N.S.H.C. 11 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
(L3Labeled Comment / Discussion for CTS 3/4.3) | |||
CTS 4.3.A.2 requires all OPERABLE control rods be exercised once every 24 hours if reactor operation continues with three or more inoperable control rods. The original intent of this requirement was to assure the reliability of the remgining OPERABLE control rods if pov er operations were to continue with three or more non fully inserted, inoperable control roc's. If the inoperable control rods were fully incerted and disarmed, they would not be considered inoperable (CTS 3.3.A.2.c) and the increased SURVF.lLLANCE FREQUENCY would not apply. | |||
The proposed requirement for contret rods that are inoperable but not stuck (LCO 3.3.B.1, ACTION C), is to fully insert and disarm the inoperable rod (s). Since continued power operation with non-fully inserted, inoperable control rods will not be allowed, there will be no requirement to exercise the OPERABLE rods to verify their operability other than the scheduled surveillance requirements in proposed SR 4.3.B.1.1 and SR 4.3.B.1.2. | |||
CTS 4.3.A.2 also requires all OPERABLE control rods be exercised once every 24 hours if reactor operation continues with a stuck control rod for which CRD mechanism failure has not been ruled out. For a stuck control rod, regardless of the reason, the proposed requirement will require all OPERABLE rods to be inserted at least one notch within 24 hours. This will verify the stuck control rod is not caused by a generic failure that would interfere with scram capability. Thereafter, continued testing of control rods will be at the normal frequency. | |||
Operating experience has shown stuck control rods to be a rare event during power operations. | |||
1 BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
The proposed change does not increase the probability of an accident previously J evaluated because the change will not involve any physical changes to plant systems, 9tructures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. | |||
The proposed change will not increase the consequences of an accident previously evaluated because continued power operation will not be allowed with inoperable (not stuck) control rods not fully inserted and verification that all OPERABLE control rods can be inserted will be required within 24 hours after discovery of a stuck control rod. In addition, if more than one control rod is stuck the reactor must be brought to HOT SHUTDOWN within 12 hours (LCO 3.3.B.1, ACTION B.1). | |||
3/4.3 - N.S.H.C. 12 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D I SECTION 3/4.3 i REACTIVITY CONTROL l | |||
TECHNICAL CHANGES - LESS RESTRICTIVE (L3Labeled Discussion of Changes for CTS 3/4.3) (continued) | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibilRy of a new or different kind of accident from any accident previously evaluated i because of the following: | |||
) | |||
l The proposed chango will not involve any physical changes to plant systems, structures, , | |||
or components (SSCs), or the manner in which these SSCs are operated, maintained, l modified, tested, or inspected. Continued operation will only be allowed with one stuck control rod and all other inoperable control rods must be fully inserted and disarmed. | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant i reduction in a margin of safety because of the following: | |||
The purpose of this surveillance was to assure the reliability of the remaining OPERABLE control rods to insert if power operations were to continue with three or more non-fully inserted, inoperable (not stuck) control rods or one stuck control rod. | |||
Since an inoperable control rod (not stuck) can be inserted, it is not subject to the i generic failure the surveillance was intended to identify, therefore, the surveillance is not appropriate for identifying common cause failures. For a stuck rod, the verification that all OPERABLE control rods can be inserted at least one notch within 24 hours will still apply. Operating experience on control reliability has shown that additional testing at an increased frequency is unnecessary. Additionally, the proposed change is being implemented concurrer.tly with more restrictive requirements governing continued operation with stuck and inoperable control rods. These more restrictive requirements ; | |||
include fully inserting all inoperable control rods within 3 hours and requiring reactor ! | |||
shutdown within 12 hours if more than one rod is stuck. Collectively, these changes l provide assurance that when a scram is required that, at a minimum, the assumptions i used in the accident analysis (i.e., most reactive control rod fully withdrawn) will be met. | |||
l l | |||
I 3/4.3 - N.S.H.C. 13 l 1 | |||
l NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
(L4Labeled Discussion of Changes for CTS 3/4.3) in addition to verifying that the drive does not go to overtravel, CTS 4.3.B.1 also requires observance of a discemible response of the nMear instrumentation when a control rod is withdrawn the first time following a refueling outage or maintenance. An indication of a flux level change on nuclear instruments demonstrates control rod motion, but does not demonstrate that a control rod is coupled, as is the intent of existing requirement 4.3.B.I.a. | |||
Therefore, this requirement is deleted. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that l no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNP 3 in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
The proposed change eliminates the requirement to verify discernible neutron instrument response to control rod motion the first time a rod is withdrawn after refueling , | |||
or maintenance. The probability of an accident is not increased because the proposed l change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The consequences of an accident are not increased because the CRDA analysis assumes a single failure of the control rod drive system when a single control rod drops out of the core from the fully inserted position after l being disconnected from its drive and after the drive has been retracted to the fully l withdrawn position while reactor power is less than 20%. During startup and before exceeding 20% reactor power, a large percentage of the rods are fully withdrawn in the normal course of a startup. All fully withdrawn rods are subjected to verification of coupling by the overtravel test. Since the deleted surveillance was intended to identify a rod that is both uncoupled and stuck in the fully inserted position, the number of fully withdrawn rods in the normal withdrawal sequence before reaching 20% power constitutes a very large sample being use6 to identify a random and very rare event. | |||
Therefore, there is no increase in the protsability that more than one control rod will remain uncoupled and stuck in the fully inserted position without being identified. | |||
Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. | |||
3/4.3 - N.S.H.C. 14 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (L4Labeled Discussion of Changes for CTS 3/4.3) (continued) | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: ' | |||
This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. Observation ofindication of a flux level change on nuclear instruments when a control rod is withdrawn does not ensure coupling. The requirement to verify the control rod does not go to overtravel when withdrawn to the full out position, the only positive test of coupling integrity, is being retained. | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
A response to control rod motion on nuclear instrumentation is indicative that a contrni rod is following its drive, but gives no indication as to whether a control rod is coupled. | |||
Likewise, failure to have a response to rod motion on nuclear instrumentation does not indicate that a rod in uncoupled. Although operators will continue to monitor nuclear instrumentation response during control rod motion, the results are insufficiently conclusive to use the results as a surveillance test for the verification of rod coupling. | |||
The CRDA analysis assumes a single failure of the control rod drive system when a single control rod drops out of the core from the fully inserted position after being disconnected from its drive and after the drive has been retracted to the fully withdrawn ) | |||
position while reactor power is less than 20%. During startup and before exceeding 20% reactor power, a large percentage of the rods are fully withdrawn in the normal course of a startup. All fully withdrawn rods are subjected to verification of coupling by the overtravel test. Since the deleted surveillance was intended to identify a rod that is both uncoupled and stuck in the fully inserted position, the number of fully withdrawn rods in the normal withdrawal sequence before reaching 20% power constitutes a very large sample being used to identify a random and very rare event. | |||
3/4.3 - N.S.H.C. 15 l | |||
l | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 | |||
' l' REACTIVITY CONTROL l TECHNICAL CHANGES - LESS RESTRICTIVE (continued) l (L5Labeled Discussion of Changes for CTS 3/4.3) | |||
CTS 4.3.B.1 requires observation that the control rod does not go to the overtravei position after maintenance without specifying the type of maintenance. The proposed SR 4.3.B.1.3 will only require observing the control rod does not go to the overtravel position after maintenance that could affect coupling integrity. Since the purpose of the surveillance is to determine that the control rod is coupled, restricting the performance to maintenance that could affect coupling integrity is appropriate. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in , | |||
I accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for ! | |||
the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
o The purpose of this surveillance is to ensure that coupling integrity is maintained, if the maintenance that was performed does not have the potentid to affect coupling then there is no reason to suspect that the rod has become uncoupbd | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: | |||
This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
As discussed above, if the maintenance that was performed does not have the potential to affect coupling then there is no reason to suspect coupling integrity has been lost. | |||
Also, SR 3.3.B.1.3 will also require that coupling integrity be verified the next time the control rod is withdrawn to the full out position which is usually immediately after retuming the rod to service. | |||
3/4.3 - N.S.H.C. 16 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
(Le Labeled Discussion of Changes for CTS 3/4.3) | |||
CTS 3.3.B.3.a does not allow control rods to be moved when the reactor is below 20% rated 1 power, except to shutdown the reactor, unless the Rod Worth Minimizer (RWM) is OPERABLE. ! | |||
A maximum of two rods may be moved below 20% design power when the RWM is inoperable if all other rods, except those which cannot be moved with control rod drive pressure, are fully inserted. | |||
Proposed LCO 3.3.F, " Rod Worth Minimizer" will continue to require operability of the RWM below 20% of design power; however, the requirements on control rod movement are being relaxed. Proposed LCO 3.3.F ACTION A will still require suspension of control rod movement when the RWM is inoperable during Startup unless withdrawal has not been performed with the RWM inoperable in the last 12 months and a second licensed operator or other qualified member of the technical staff verifies movement of control rods is in compliance with the banked position withdrawal sequence (BPWS). The RWM function assists and supplements the operator with an effective backup control rod monitoring routine that enfo:ces adherence to established startup, shutdown, and low power level control rod procedures. Allowing a second licensed operator or other qualified member of the technical staff ?.o verify control rod movement is in compliance with BPWS also provides effective control. Not allowing more than one startup per 12 months will ensure that the RWM is maintained OPERABLE. | |||
Although CTS 3.3.B.3. allows control rod movement to shutdown the reactor without any constraints, proposed LCO 3.3.F, ACTION B will also require a second licensed operator or other qualified member of the technical staff to verify movement of control rods is in compliance with BPWS. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
The proposed change will allow either a second licensed operator or other qualified ! | |||
members of the technical staff to verify movement of control rods when the RWM is ! | |||
inoperable. The function of the RWM is to control adherence to the control rod I withdrawal and insertion sequence. The use of a second licensed operator or other qualified members of the technical staff to perform these control rod movement verifications also provides effective control. Not allowing more than one startup per 12 months with the RWM inoperable will ensure that the RWM ic maintained OPERABLE. | |||
3/4.3 - N.S.H.C. 17 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D L SECTION 3/4.3 REACTIVITY CONTROL l | |||
TECHNICAL CHANGES - LESS RESTRICTIVE (Le Labeled Discussion of Changes for CTS 3/4.3) (continued) | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the | |||
, possibility of a new or different kind of accident from any accident previously evaluated because of the following: | |||
This proposed change will not involve any physical changes to plant systems, I structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. Compliance with the requirement to follow the BPWS are still maintained. | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
The proposed change will limit control rod movement verification when the RWM is inoperable, to once per 12 months. Only licensed operators or other qualified members of the technical staff (i.e., personnel trained in accordance with an approved training l program) will be allowed to verify control rod movement. Each of these individuals, as a l part of their qualification process, receive training in the use of the RWM, the Control Rod Drive System, and permissible control rod sequences. | |||
1 O | |||
i l 3/4.3 - N.S.H.C. 18 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
(L7Labeled Discussion of Changes for CTS 3/4.3) | |||
CTS 4.3.B.3.a requires verifying the correctness of the control rod withdrawal sequence input to the RWM computer prior to control rod withdrawal for startup and prior to insertion to reduce power below 20%. This requires verification for each plant startup and shutdown. Proposed SR 4.3.F.3 will require this verification only once following loading of the sequence into the RWM computer. | |||
The potential for error occurs when the sequence is initially loaded into the computer. Once the rod withdrawal sequence is verified, controls are in place to ensure that changes cannot be made without prior approval. Any change would require reverification. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that , | |||
no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?. | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following. | |||
The RWM does not monitor core thermal conditions, but simply enforces preprogrammed rod patterns as a backup intended to prevent reactor operator error in selecting or positioning contrd rods. Once the sequence is loaded into the RWM computer and verified, there is no reason to believe that it will change inadvertently. | |||
Controls are in place to ensure that required changes are performed and verified by technically qualified individuals. | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated , | |||
because of the following: , | |||
This proposed change will not involve any physical changes to plant systems, stre:tures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, cd inspected. | |||
3/4.3 - N.S.H.C. 19 | |||
l NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (L7Labeled Discussion of Changes for CTS 3/4.3) (continued) | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
The RWM does not monitor core thermal conditions, but simply enforces preprogrammed rod patterns as a backup intended to prevent reactor operator error in selecting or positioning control rods. Once the sequence is loaded into the RWM i computer and verified there is no reason to believe that it will change inadvertently. ! | |||
Controls are in place to ensure that required changes are performed and verified by ! | |||
technically qualified individuals. | |||
i l | |||
l 3/4.3 - N.S.H.C. 20 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
(La Labeled Discussion of Changes for CTS 3/4.3) | |||
CTS 3.3.F states that " Specifications 3.3.A through D above do not apply when there is no fuel in the reactor vessel." This implies that Specifications A through D must be met during all MODES of operation when there is fuel in the reactor vessel. In the HOT SHUTDOWN and COLD SHUTDOWN MODES, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod OPERABILITY during these conditions. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling conditions. Therefore, proposed LCOs 3.3.B.1 is revised to require APPLICABILITY only in the RUN and STARTUP MODES, or REFUEL MODE when the reactor vessel head is fully tensioned. Since control rod scram times and control rod scram accumulators are conditions for control rod OPERABILITY, LCOs 3.3.C and 3.3.D are also revised accordingly. In addition, there are no design bases accidents (DBAs) or abnormal operational transients (AOTs) identified for conditions when one or less control rods are withdrawn that require a scram. Because the proposed changes do not require APPLICABILITY in all MODES, they are less restrictive. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards: | |||
: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: | |||
Control rod OPERABILITY is required to ensure reactivity control and power level control and to mitigate the consequences of design basis accidents (DBAs) or abnormal operational transients (AOTs). The station safety analysis does not identify any DBAs or (AOTs) that require control rod scram under conditions where no more than one control rod is with drawn. In the HOT SHUTDOWN and COLD SHUTDOWN M00ES, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied, in the REFUEL MODE, only one control rod can be withdrawn. This provides adequate requirements for control rod OPERABILITY during these conditions. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the controi rods and to prevent criticality during refueling conditions. | |||
3/4.3 - N.S.H.C. 21 | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (La Labeled Discussion of Changes for CTS 3/4.3) (continued) | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: | |||
This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
The proposed change will continue to require control rod OPERABILITY, scram function, and accumulator OPERABILITY during plant conditions requiring reactivity control to mitigate the consequences of DBAs and AOTs. The changes do not impact the ability of equipment to maintain the plant within acceptable limits and continues to provide assurance that plant operation is maintained within safety analysis assumptions. | |||
3/4.3 - N.S.H.C. 22 | |||
l l | |||
1 NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) | |||
(Le Labeled Discussion of Changes for CTS 3/4.3) | |||
CTS 3.3.E requires the reactivity equivalent of the difference between the actual critical rod configuration and the expected configuration during power operation. CTS defines REACTOR POWER OPERATION as any operation with the mode switch in the "STARTUP" or "RUN" position with the reactor critical and above 1% design power. The core reactivity anomaly , | |||
surveillance must be performed under steady state operations (no control rod movement or ] | |||
core flow changes in progress) because of the small (< 1%) changes being evaluated. This is l best performed after the generator is synchronized to the grid which requires the mode switch to be in RUN. Therefore, proposed LCO 3.3.E is revised to be applicable only in the RUN MODE. Since proposed LCO 3.3.E will no longer be applicable in the STARTUP MODE, this change is less restrictive. | |||
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for l | |||
the three categories of the significant hazards consideration standards: | |||
; 1. Does the change involve a significant increase in the probability or consequences of an | |||
! accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously 1 evaluated because of the following: ! | |||
The reactivity anomaly LCO provides a simple comparison of predicted versus actual conditions and is not an initial condition of a design oasis accident (DBA) or abnormal operational transient (AOT). | |||
: 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? | |||
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated oecause of the following: | |||
Reactivity anomaly is not a structure, system, or component, therefore, this proposed change will not involve any physical changes to the plant or the manner in which the plant is operated. | |||
3/4.3 - N.S.H.C. 23 a | |||
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (Le Labeled Discussion of Changes for CTS 3/4.3) (continued) | |||
: 3. Does this change involve a significant reduction in a margin of safety? | |||
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: | |||
The reactivity anomaly is not an inP.ial condition of a design basis accident (DBA) or abnormal operational transient (AOT). Also, in the STARTUP MODE, enough operating margin exists to limit the effects of a reactivity anomaly, and thermal power is low enough (s; 5% RTP) such that reactivity anomalies are unlikely to occur. | |||
l 1 | |||
l 3/4.3 - N.S.H.C. 24 | |||
i l | |||
l l | |||
l 1 | |||
l l | |||
l Attachment E I Proposed Final Technical Specification Pages and Bases 1 | |||
) | |||
1 i | |||
: TABLE OF CONTENTS 1.0. DEFINITIONS 1-1 2.0 SAFETY LIMITS 2-1 2.1 Safety Limits 2-1 2.2 Safety Limit Violation 2-1 BASES B2-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.1 REACTOR PROTECTION SYSTEM 4.1 3/4.1-1 BASES B3/4.1-1 3.2 PROTECTIVE INSTRUMENTATION 4.2 3/4.2-1 A. Primary Containment isolation Functions A 3/4.2-1 B. Core and Containment Cooling Systems B 3/4.2-1 C. Control Rod Block Actuation C 3/4.2-2 D. Radiation Monitoring Systems D 3/4.2-2 E. Drywell Leak Detection E 3/4.2-3 F. Surveillance Information Readouts F 3/4.2-3 ' | |||
G. Recirculation Pump Trip / Altemate Rod G Insertion 3/4.2-4 H. Drywell Temperature H 3/4.2-5 BASES B3/4.2-1 3.3 REACTIVITY CONTROL 4.3 3/4.3-1 A. Reactivity Margin - Core Loading A 3/4.3-1 B. Control Rod Operability B 3/4.3-2 C. Scram insertion Times C 3/4.3-7 D. Control Rod Accumulator D 3/4.3-8 E. Reactivity Anomalies E 3/4.3-10 F. Rod Worth Minimizer (RWM) F l 3/4.3-11 l G. Scram Discharge Volume G 3/4.3-12 J H. Rod Pattem Control H 3/4.3-13 BASES B3/4.3-1 i 3.4 STANDBY LIQUID CONTROL SYSTEM 4.4 3/4.4-1 BASES B3/4.4-1 3.5 CORE AND CONTAINMENT COOLING 4.5 3/4.5-1 SYSTEMS A. Core Spray and LPCI Systems A 3/4.5-1 B. Containment Cooling System B 3/4.5-3 C. HPCI System C 3/4.5-7 D. Reactor Core isolation Cooling (RCIC) System D 3/4.5-8 E. Automatic Depressurization System (ADS) E 3/4.5-9 4 F. Minimum Low Pressure Cooling and Diesel F Generator Availability 3/4.5-10 | |||
' G. (Deleted) G 3/4.5-11 | |||
'H. Maintenance of Filled Discharge Pipe H 3/4.5-12 BASES B3/4.5-1 PNPS i Amendment No. l | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REACTIVITY CONTROL A. Reactivity Marain - Core Loadina A. Reactivity Marain - Core Loadino LCO 3.3.A.1 SR 4.3.A.1 The core loading shall be limited to that Sufficient control rods shall be which can be made subcriticalin the withdrawn following a REFUELING most reactive condition during the OUTAGE when CORE ALTERATIONS l OPERATING CYCLE with the strongest were performed to demonstrate with a OPERABLE control rod in its full-out margin of 0.25 percent Ak that the core position and all other OPERABLE rods can be made subcritical at any time in I fully inserted. the subsequent fuel cycle with the strongest OPERABLE control rod fully APPLICABILITY: withdrawn and all other OPERABLE At all times when there is fuelin the reactor vessel. | |||
ACTIONS: | |||
A. LCO 3.3.A.1 cannot be met. | |||
1 Be in HOT SHUTDOWN within 12 hours. | |||
l l | |||
l PNPS 3/4.3-1 Amendment No. l | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued)- 4.3 REACTIVITY CONTROL (continued) | |||
B. Control Rod Operability B. Control Rod Operability LCO 3.3.B.1 SR 4.3.B.1.1 NOTE-- | |||
Each control rod shall be OPERABLE. Not required to be performed until 7 days after the control rod is withdrawn ' | |||
APPLICABILITY: and thermal power is greater than the l LPSP of the RWM. | |||
RUN and STARTUP MODES; REFUEL . | |||
MODE when tne reactor vessel head is insert each fully withdrawn OPERABLE fully tensioned. (See also 3.10.D) control rod at least one notch once per ACTIONS A. One withdrawn control rod stuck. | |||
NOTE - - | |||
NOTE - Not required to be performed until Rod Worth Minimizer (RWM) may 31 days after the control rod is , | |||
be bypassed as allowed by LCO withdrawn and thermal power is greater | |||
{ | |||
3.3.F. than the LPSP of the RWM. | |||
1 Verify stuck control rod is Insert each partially withdrawn j separated from other OPERABLE control rod at least one inoperable control rods by notch once per 31 days. | |||
two or more OPERABLE control rods immediately. SR 4.3.B.1.3 AND Verify each withdrawn control rod does not go to the withdrawn overtravel 2 Disarm the associated position. | |||
control rod drive (CRD) within 2 hours. a. Each time the control rod is withdrawn to " full out" position. | |||
3 Perform SR 4.3.B.1.1 and AND SR 4.3.B.1.2 for each b. Prior to declaring control rod withdrawn OPERABLE OPERABLE after work on control control rod within 24 hours rod or CRD system that could from discovery of affect coupling. | |||
condition A concurrent with thermal power greater than SR 4.3.B.1.4 the Low Power Setpoint Verify each control rod scram time from (LPSP) of the RWM. | |||
fully withdrawn to notch position 04 is AND s 7 seconds in accordance with 4 Verify LCO 3.3.A.1 is met SR 4.3.C.1 or SR 4.3.C.2. | |||
within 72 hours. | |||
SR 4.3.B.1.5 AND Determine the position of each control (continued) rod once per 24 hours. | |||
PNPS 3/4.3-2 Amendment No. | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
B. Control Rod Operability (continued) B. Control Rod Operability (continued) | |||
LCO 3.3.B.1 (continued) 5 - | |||
NOTE Not applicable when thermal power > 20% RTP. | |||
Ensure stuck rod is in compliance with banked position withdrawal sequence (BPWS) sequence within 8 hours. | |||
M Verify control rod drop accident limit of 280 cal /gm is not exceeded within 8 hours. | |||
B. Two or more withdrawn control rods stuck. | |||
1 Be in HOT SHUTDOWN within 12 hours. | |||
C, - | |||
NOTE-Separate condition entry is allowed for each control rod. | |||
One or more control rods inoperable for reasons other than condition A or B. | |||
1 --NOTE - | |||
RWM may be bypassed as allowed by LCO 3.3.F. l i | |||
Fully insert inoperable control rod within 3 hours. | |||
AND 2 Disarm the associated j CRD within 4 hours. ' | |||
(continued) l PNPS 3/4.3-3 Amendment No. l ! | |||
f | |||
LIMITING CONDITIONS FOR OPERATL.4 SURVEILLANCE REQUIREMENTS l 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
: 8. Control Rod Operabi;ity (continued) B. Control Rod Operability (continued) | |||
LCO 3.3.B.1 (continued) | |||
D. NOTE Not applicable when thermal power > 20% RTP. | |||
Two or more inoperable control rods not in compliance with BPWS and not separated by two or more OPERABLE control rods. | |||
1 Restore compliance with BPWS within 8 hours. | |||
M 2 Verify control rod drop accident limit of 280 cal /gm is not exceeded within 8 hours. | |||
!3 Restore control rod (s) to OPERABLE status within 8 hours. | |||
E. - | |||
NOTE -- | |||
Not applicable when thermal power > 20% RTP. | |||
One or more groups with four or more inoperable control rods. | |||
1 Restore control rod (s) to OPERABLE status within 8 hours. | |||
F. Required action and associated completion time of condition A, C, D, or E not met. | |||
M Nine or more control rods inoperable. | |||
1 Be in HOT SHUTDOWN within 12 hours. | |||
PNPS 3/4.3-4 Amendment No. | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
B. Control Rod Operability (continued) B. Control Rod Operability (continued) | |||
LCO 3.3.B.2 SR 4.3.B.2 The control rod drive housing support The control rod drive housing support system shall be in place. system shall be inspected after reassembly and the results of the APPLICABILITY: inspection recorded. | |||
During reactor power operation and when the reactor coolant system is pressurized above atmospheric pressure with fuel in the reactor vessel. | |||
ACTIONS: | |||
A. LCO 3.3.B.2 cannot be met. | |||
1 Be in COLD SHUTDOWN within 24 hours. | |||
i l | |||
4 PNPS 3/4.3-5 Amendment No. l | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
B. Control Rod Operability (continued) 8. Control Rod Operability (continued) | |||
LCO 3.3.B.3 SR 4.3.B.3 Control rods shall not be withdrawn for Prior to control rod withdrawal for startup unless at least two source range startup, verify that at least two source channels have an observed count rate range channels have an observed equal to or greater than three counts count rate of at least three counts per per second. second. | |||
APPLICABILITY: , | |||
I Prior to withdrawing control rods for i startup. I ACTIONS: | |||
A. LCO 3.3.B.3 cannot be met. | |||
1 Place the mode switch in shutdown immediately. | |||
PNPS 3/4.3-6 Amendment No. | |||
LIMITING CONDITIONS FOR OPERATION SURVElLLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
C. Scram insertion Times C. Scram insertion Times LCO 3.3.C SR 4.3.C.1 1 Average scram insertion time for all Following each REFUELING OUTAGE, l OPERABLE control rods from de- or after a reactor shutdown that is energization of the scram pilot valve greater than 120 days, each solenoids to dropout (DO) of OPERABLE control rod shall be I notches 04,24,34, and 44 shall be subjected to scram time tests from the no greater than: fully withdrawn position. If testing is not accomplished with the nuclear system Notch Average Scram pressure above 950 psig, the measured Pesition Times (seconds) scram insertion time shall be 44 DO 0.508 extrapolated to reactor pressures above 34 DO 1.252 950 psig using previously determined 24 DO 2.016 correlations. Testing of all OPERABLE 04 DO 3.578 control rods shall be completed prior to exceeding 40% rated thermal power. | |||
2 Average scram insertion time for the three fastest OPERABLE control SR 4.3.C.2 rods in each group of four control Within each 120 days of operation, a rods in all two by two arrays from de-energization of the scram pilot minimum of 10% of the control rod valve solenoids to dropout (DO) of drives, on a rotating basis, shall be notches 04,24,34, and 44 shall be scram tested as in SR 4.3.C.1. An I n greater man. evaluation shall be completed every 120 days of operation to provide Notch Average Scram reasonable assurance that proper Pesition Times (seconds) pedormance is be,ng i maintained. | |||
44 DO 0.538 34 DO 1.327 24 DO 2.137 04 DO 3.793 APPLICABILITY: | |||
RUN and STARTUP MODES; REFUEL MODE when the reactor vessel head is fully tensioned. | |||
ACTIONS: | |||
A. LCO 3.3.C cannot be met. | |||
1 Be in HOT SHUTDOWN within 12 hours. | |||
PNPS 3/4.3-7 Amendment No. l | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
D. Control Rod Accumulators D. Control Rod Accumulators LCO 3.3.D SR 4.3.D Each control rod scram accumulator shall be OPERABLE. Once a shift, check the status of the ressure and leve.' alarms for each APPLICABILITY: accumulator. | |||
RUN and STARTUP MODES; REFUEL MODE when the reactor vessel head is fully tensioned. | |||
ACTIONS: | |||
NOTE , | |||
Separate condition entry is allowed for each control rod scram accumulator. | |||
A. Control rod scram accumulator (s) inoperable with reactor steam j dome pressure 2 950 psig. l 1.1 Verify no adjacent OPERABLE control rod has an inoperable scram ; | |||
accumulator within 1 1 hour. | |||
AND 1.2 Verify no adjacent control rod is electrically disarmed in a non-fully inserted position within 1 hour. | |||
2 Declare the associated control rod inoperable within 1 hour. | |||
B. Control rod scram accumulator (s) inoperable with reactor steam dome pressure < 950 psig or reactor thermal power s; 20 % RTP. | |||
1 Restore inoperable accumulator to OPERABLE status within 8 hours. | |||
2 Declare the associated control rod inoperable 1 within 8 hours. | |||
(continued) | |||
PNPS 3/4.3-8 Amendment No. | |||
i 1 | |||
LIMITING CONDITIONS FOR OPERATION {iURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
D. Control Rod Accumulatoa (continued) D. Control Rod Accumulators (continued) | |||
LCO 3.3.D (continued) | |||
C. Two or more control rod accumulators inoperable, concurrent with loss of charging water pressure, when reactor j steam dome pressure 2 950 psig. | |||
1 Restore charging water header pressure within 20 minutes. | |||
AND 2 Restore inoperable accumulator (s) to OPERABLE status within 8 hours. | |||
D. Two or more control rod accumulators inoperable, concurrent with loss of charging water pressure, when reactor steam dome pressure < 950 psig. | |||
1 Verify all control rods associated with inoperable accumulators are fully inserted immediately. | |||
AND 1 1 | |||
2 Declare the associated control rods inoperable within i hour. | |||
E. Required action and associated completion time if C.1 or D.1 not j met. | |||
1 - | |||
NOTE l Not applicable if all l inoperable control rod I scram accumulators are associated with fully inserted control rods. | |||
Place the reactor mode - | |||
switch in the shutdown position immediately. | |||
PNPS 3/4.3-9 Amendment No. l 1 | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
E. Reactivity Anomalies E. Reactivity Anomalies LCO 3.3.E SR 4.3.E The reactivity equivalent of the During startups following REFUELING difference between the actual critical OUTAGES, the critical rod rod configuration and the expected configurations will be compared to the configuration shall not exceed 1% AK. expected configurations at selected operating conditions. These APPLICABILITY: comparisons will be used as base data RUN MODE | |||
'** Y * "" ""9 """9 subsequent power operation throughout ACTIONS: the fuel cycle. At speciiic power operating conditions, the critical rod A. Limit exceeded. configuration will be compared to the configuration expected based upon 1 Be in HOT SHUTDOWN appropriately corrected past data. This within 12 hours. comparison will be made at least every full power month. | |||
PNPS 3/4.3-10 Amendment No. | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
F. Rod Worth Minimizer (RWM) F. Rod Worth Minimizer (RWM) | |||
LCO 3.3.F SR 4.3.F.1 The RWM shall be OPERABLE. Perform an INSTRUMENT FUNCTIONAL TEST of the RWM prior APPLICABILITY: to control rod withdrawal for startup or RUN and STARTUP MODES with reactor thermal power s; 20 % RTP. SR 4.3.F.2 ACTIONS: Verify the RWM automatic bypass setpoint to be > 20% RTP every 24 A. RWM inoperable during reactor months. | |||
startup. | |||
l SR 4.3.F.3 l 1 Immediately suspend control rod movement Verify control rod sequences input to except by scram. the RWM are in conformance with O R- BPWS prior to declaring RWM OPERABLE following loading of 2.1 Immediately verify by sequence into RWM. | |||
administrative methods that startup with RWM inoperable has not been performed in the last 12 months. | |||
AND 2.2 Verify movement of control l | |||
rods is in compliance with BPWS by a second licensed operator or other qualified member of the technical staff during control rod movement. | |||
B. RWM inoperable during reactor shutdown. | |||
1 Verify movement of control rods is in accordance with BPWS by a second licensed operator or other qualified member of the technical staff during control rod movement. | |||
PNPS 3'4.3-11 Amendment No. l | |||
I LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS , | |||
3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
G. Scram Discharae Volume G. Scram Discharae Volume LCO 3.3.G SR 4.3.G 1 The scram discharge volume drain & Verify scram discharge volume drain vent valves shall be OPERABLE. and vent valves open at least once per month. | |||
APPLICABILITY: | |||
SR 4.3.G.2 i RUN and STARTUP MODES; l REFUEL MODE when the reactor Test scram discharge volume drain and j vessel head is fully tensioned. vent valves as specified in 4.13. These valves may be closed intermittently for ACTIONS: testing under administrative control. | |||
A. Any scram discharge volume drain SR 4.3.G.3 or vent valves made or found inoperable. During each REFUELING INTERVAL verify the scram discharge volume drain 1 Be in HOT SHUTDOWN and vent valves. | |||
within 12 hours. | |||
a Close within 30 seconds after receipt of a reactor scram signal. l AND b Open when the scram is reset. | |||
I l | |||
l l | |||
I | |||
) | |||
I i | |||
I l | |||
l l | |||
l l | |||
PNPS 3/4.3-12 Amendment No, l l | |||
2 | |||
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) | |||
H. Rod Pattern Control H. Rod Pattern Control LCO 3.3.H SR 4.3.H All OPERABLE control rods shall Verify all OPERABLE control rods comply with the requirements of the comply with BPWS every 24 hours. | |||
BPWS. | |||
APPLICABILITY: | |||
RUN and STARTUP MODES with reactor thermal power s 20 % RTP. , | |||
1 ACTIONS I | |||
A. One or more OPERABLE control j rods not in compliance with BPWS. | |||
l I | |||
NOTE RWM may be bypassed as allowed by LCO 3.3.F. { | |||
l Move associated control l rod (s) to correct position within 8 hours. | |||
M 2 Verify control rod drop accident limit of 280 caligm is not exceeded within 8 hours. | |||
M 3 Declare associated control rod (s) inoperable within 8 hours. | |||
(continued) | |||
PNPS 3/4.3-13 Amendment No. l | |||
r LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS | |||
( 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) i l H. Rod Pattern Control (continued) H. Rod Pattern Control (continued) l LCO 3.3.H (continued) , | |||
I l B. Nine or more OPERABLE control rods not in compliance with BPWS. , | |||
1 NOTE RWM may be bypassed as , | |||
allowed by LCO 3.3.F. | |||
Immediately suspend withdrawal of control rods. | |||
AND 2 Place the reactor mode switch in the shutdown position within 1 hour. | |||
l PNPS 3/4.3-14 Amendment No. | |||
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Latest revision as of 06:24, 13 November 2020
| ML20196D024 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/16/1999 |
| From: | BOSTON EDISON CO. |
| To: | |
| Shared Package | |
| ML20196D012 | List: |
| References | |
| NUDOCS 9906240177 | |
| Download: ML20196D024 (76) | |
Text
{{#Wiki_filter:i Attachment B Markups of Current Technical Specification Pages 9906240177 990616 T PDR ADOCK 05000293'-
' P PDR I
~ l TABLE OF CONTENTS 1.0 DEFINITIONS 1-1 2.0 SAFETY LIMITS 2-1 2.1 Safety Limits 2-1 2.2 Safety Limit Violation 2-1 BASES B2-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.1 REACTOR PROTECTION SYSTEM 4.1 3/4.1-1 BASES B3/4.1-1 3.2 PROTECTIVE INSTRUMENTATION 4.2 3/4.2 1 A. Primary Containment Isolation Functions A 3/4.2-1 B. Core and Containment Cooling Systems B 3/4.2-1 C. Control Rod Block Actuation C 3/4.2 2 ) D. Radiation Monitoring Systems D 3/4.2-2 E. Drywell Leak Detection j E 3/4.2-3 F. Surveillance Information Readouts F 3/4.2-3 G. Recirculation Pump Trip / Alternate Rod G Insertion 3/4.2-4 H. Drywell Temperature H 3/4.2-5 , BASES B3/4.2-1 ! 3.3 REACTIVITY CONTROL . 4.3 3/4.3-1 A. Reactivity Margin - Core Loading? :ctMty A 3/4.3-1 L4m4ations B. Control Rod Operability B 3/4.3-2 C. Scram insertion Times C 3/4.3-7 D. Control Rod Accumulator D 3/4.3-8 E. Reactivity Anomalies E 3/4.3-10 F. Rod Worth Minimizer (RWM) .^! tem:tc F 9q@emente 3/4.3-11 G. Scram Discharge Volume G 3/4.3-12 H. Rod Pattem Control H 3/4.3-13 BASES B3/4.3-1 3.4 STANDBY LIQUID CONTROL SYSTEM 4.4 3/4.4-1 BASES B3/4.4-1 3.5 CORE AND CONTAINMENT COOLING 4.5 - 3/4.5-1 SYSTEMS A. Core Spray and LPCI Systems A 3/4.5-1 B. Containment Cooling System B 3/4.5-3 C. HPCI System C 3/4.5-7 D. Reactor Core isolation Cooling (RClC) System D 3/4.5-8 E. Automatic Depressurization System (ADS) E 3/4.5-9 F. Minimum Low Pressure Cooling and Diesel F Generator Availability 3/4.5-10 G. (Deleted) .. G 3/4.5-11 H. Maintenance of Filled Discharge Pipe H 3/4.5-12 BASES B3/4.5-1 PNPS i Amendment No. i
ATTACHMENT B LIMITING CONDITIONS FOR OPERATI@ SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REACTIVITY CONTROL i..a mm,.1 _- ui.,.1...
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loadina - A. lhl Reactivity maroin - core
> loadina I- The core loading shall be .
0 33M limited to that which can be &# Sufficient control rods shall ' made subcritical in the most . be withdrawn following a reactive condition during the Aa' refueling outage when core Ap;- operating cycle with the alterations were performed to strongest operable control rod demonstrate with a margin of in its full-od position and 0.25 percent Ak that the core all other operable rods fully can be made subcritical at any
, inserted, time in the subsequent fuel cycle with the strongest ib- necrti.it, marc:- i;ccerchie operable control rod fully en'-" - -t . withdrawn and all other
% operable rods fully inserted.
er Contrci rod drivcc which can .c bc mcvcd with control h "r"rt i cit- -- ;i- : m crabic red drive prcacurc cheH-be cor:rcl - "^ considerrd inopcrcbic. !f r s.c Insest i : . . , prrtially or fully .ithdrcun " Each particily or fully
> W 8AB.1 ? + 3=
control rad drive canact bc em"e.sau withdrawr operabic control rod ACTIONS A & S _____a a_. SR 4.8.813 ,m,u.._,.,.
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; 1 Coat encc pcr 2' hour; ir the unic3; ;nvc;tigation cvcnt pcucr opcratic. is demonstectcc that the cause continuing with tPrcc or marc the failurc la not duc to inopcrobic control rod; or in c failed contrel red drive the cvcat pcucr opcration la mechanium ccIlet 'cusing. continuing witt rne fully c:
E Ar. 4 IAPPLICABILITY: ~ t N [_ m-...~- - ~ N . - - 5. ', . "'. h..m k .. At all times when there is fuelin the reactor control rod drivc mcchanic vesse damagc hc not bcci rulcd out. ACTIONS:\ %.
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tl A. LCO 3 3.A.1 cannot be met,
.As 1 Be in HOT SHUTDOWN x within 12 hours o :. .= n177 x -
Amendment NO-44 3/4.3 1
1' ATTACHMENT B LIMITING CONDITIONS FOR OPERATIOE SpRVEILLANCE RE9UIREMENTS 3.3 REACTIVITY CONTROL (Cont) 4.3 REACTIVITY CONTROL (Cont) n _ .m ,
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___u, rod once per 24 hours. I
- ACTION O '
y , ...,.. .m. , ._- x. - - . .
. 1
- a. . , , _ .sm
_ .u_. *. L..._ ____! - ._A ...~ "u .. SR 4 3 B 14 ' 3_.._ s. m s. . m. m m.~m v s. . . . m s. - mr Venfy each control rod scrum time from fully M.4 c _ _ _1 e i , . m __ , , n , ___ , M'8 "r"_^'_'","'""..**',,.'u"_".'_. u u withdrawn to notch E*sition 04 ls 5 7 seconds 1 ._~ y s_. ._ m m
. n_ , um .. m. s.,
-..u_ ..
~~ in accordance with SR 4 3 C.1 or SR 4.3 C.2.
.__._s ___ _ ,
gp ~.- -.u m s.~...v. .-- A A m..1..- .- t.00 3.8.S.1
- e*-"*- '~i' -- - - -" --'
- '~-'
SR 4 3 B.1.3 N M'7 ACTION E dicarmed c1ec ricc1l'i . ' Verify each withdrawn control rod i does not go to the withdrawn iA7 - er n.._:__
- . . ..3
.m..~m. ym m m y s . _. 1_..,
s.. overtravel position. 1r ..._L. __ _c t u. ~_ ~ . mm s. . v. . _ _ _ ._eMe
.f .~ys.
F. Requked action ard _g _ m ._
,_m..,..3 .vm _ m,. _u..,,..
m
.~m mm-m
..___a c.___
completion tame of -# _m.v _ u... s. . m ys.~ .1c.,__m_.s.
. 2v.. , ,
_ _ ., . s . e 4 condmon A, C, D or _.._u_ 1_.
" ' ' " " '~ ' --. - "" " . . . _i, ."" ""'
E. not met. B. Control Rode, ODerability (A2
% {
__.a. m ,no,, +r +t-tHefh.- r- - - - s.
. - - - --.~~
.._.,.._.._a m
p* ** __._,1_
*~r
..___..._m,, u_
control rode -.m u. . mu.___ .- s ., t, __ ____ m ~s -.m_,m.
.. _ , ,,_ ,'"'_'J,
***'-MJ
___u ..,ua_""._* ' * *^ > i inoperable. _a_ .1u -- - - ~ - -- - - - ~ ~ ' ""
-_ -.m _~-.m.
~ . . . . _ . _ . _.m..
. _ _____ _ _ , . _, _ _ m,,__.
t _.._I_.. f_.. 3- _ . . _ _ _ . . _f ""'V*' 'V"* "'"# *V^*V"#
- 1 se in hot - ~ ' - --- -- s^-- j
_._.a_"~_c__ i swToom
.nn r"-- ." s'e Nn 12 hours.
_.._.._13,
+-'-s"'"~"-
.2____. _c e7 m__
~' -'-
-u_ _a
-v" - .: m __.._
"*u~~"""
_n__ :m .. _ , ..,.o. , , _ ,__m _ . . _
+u~ --- - ci -
r__
~ ~- ~w .m_.e l
, s. .- m . ~ s-Ms ___m _,
.w.._,m,.1_ .'. yv mmuw _ __
. y1.- pcr ,,-dayer l
- r. m. .
mm. ._,_,.s__~_.._,
~ . . . .
_m__.._
--s..
v. B.
'A- 22_____ru,_ _ _ _ _ _ . _ _ ., .u Cont rol Rodh Operabili tv. l -2 "+"--"-~*-
- ~ r v"-
.mmm.mm~m,.
v+ 1_..
~~
.m.. . v. .
4v "ac'. control rod chcIl bc D 'C"Cr* UT 1010101 20d3
-y.-
,.a
>_2.._
m ... ..
.L' 4 #~ " ~- r - - - --~~-
dicccrnibic, Cubac scnt
%nW completely ;r'crted and thc Control rod direct ioncE-of en. .--*"'"U
_ _ _1 _ 2 _ _c .u_ _a_
.u control /cl^.c3 dicar .cd e.cm.._ mm
.mmm.
1_ m
.a. s. ,. s. .__m_1_,,.,.. .. gm . y. . . m ~ . m
____m m . 2,_ ,.. . _ _u.~.. , , u.__ y . .c , .____a.
,~,
.u__ .._ .:
mvm,
~m m yy . .,.
z_
.u_
s.~ __t..,_,
. s. m .. .
. , , , .. ..r,.. 2_._.,___.._._
mm. mmm .v.. sv.~r i __a :__ .. u _
..u._. . w w w i v .- .' o rc;P;n3C-
. . . .~ s..~
M7 i
.__,.._2 , . . _ ___. __, ._ 2 .a v
.s.. . - , -m.m. -m m:. . ..-. _ _ l
. ~_ _ . , .m u ,_ ___.._a N ,
I r___ ,,_m .~~.s.",- -"s -
- a. Each tirne the control rod is withdrawn to "fud out" +- -- - I my_.-~
__.~m . pom on. j f-AND b Pnor to dectanng control rod OPERABLE after , Ls I. work on control rod or CRD system that could om:,.w 477 affect coupl.ng. 4 m . - ..
/ 1 Amendment NoA4424 3/4.3-2
n ATTACHMENT B kIMITING CONDITIONS FoR OPERATION SyRVEILI.ANCE REoUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REACTIVITY CONTROL A.2 B. Control Rods' (C^^t) OPERABILITY _ B. Control Rod; (Cent)OPERABILITYj _ LCO 3 3 8 2 & The' control rod drive housTn'g qsup~ port sy< stem shall be in pla]c.e:-
. k
*i t.^. ten the red 20 r"t5dr r;- the " ret time,
- f. *e . 4 ~__ _- s - - .
jd.unng reactor powerapeation and' r : ;uent te e:L L.' APPUCABluTY: when the reactor coolant system is -a ^ or-afted g,refur!!n"g^ut-^;Ete^1e~that pressunzed above atmospheric .0'ntenen - p pressure with fuelin the reactor tEdJ-M: not go to the, elm _s e_.l ,'"..^.__' _. -- -". ~~. .'.. .U. . ^_ d _ ,_.- ~ _ .
^. .". -. ~ . . " ... " .r^ ' ~ ~ * - ^ ^ -
J' 1 rl. a.it.h,,
. . . In a,. a_ A,em.A. C r------ mneine a.im.- n ~
Ag' Af 1 QQA....41. . . . . . . AM6sg K f~ d. ] The control rod drive housing (b43 B] support system shall be A. LCO 3 3 B 2 cannot be met.
- in COLD SHUTDOWN inspected after reassembly and twi 24 hours. / the results of the inspection I recorded.
& a: No contre! r^de the!! ba acred fM._4 3 F i Perform an INSTRUEIENT
- FUNCT1oNKL TEs u..,w. .a_n,6.s. .n,. .,a_a_n.m_ _ _ . , l..e. u_ _ l.m_ u. .s _O n. 0,L,,
d' L_Qr]- Pnor to control rod withdrawal for
._ . a_ nm. ...., o_ _m ,. _ m. . m c . . . _ r . .- startup or insertior. to reduce .
wm.a_ m_ m. .m .u.. , _ _.,, _m_ , m_ ,. u - ,.
. . _ ., . . . - - _ power below 20%,of-the i
.wn.
. . . .o.. ma_ \.A./m.., . . w L.Ainim..l.,a., /.o t.A A.,i
. s ..
we_ r. _a w n.; A.,, m.f....h.. I, mm., akin A' m e wima am mi .um i D. M_ i.A.fM.. .s. , 4 _ g.. ..r-'---' ' ' - " ' ' " ' ' ' ' - ' - - - - gg;,;,n;,,, f o. ,tg A ---f-.--. I-.--...-- m a i e x aH. u.-.
- gao3A.s . , m a ,
. - - . .n.. m,. w . . m..m.m-ma ut,uu. emot Im, ,: w ,, ,
a ,. --. . .- - m u,, .u o s A = A I,. t . . x. . . a_ ___.,.'r----'"'" " ' - - ' " " r,mm.,.wim i, on m u, 'ma,. m.x,.a.,,..u Q, .: r--- "" " ' "--- ,_ "'",u-"'"" ,.m,m ,.,m,,- - - - - ' - " ', , ,
....m. .u' ,."m m 1,'.s n m_. u .'u'" .a ,','a.u,
-r--""'"' ' " ' " " I' m, .m
,.,..-.'.r---'"='"--'"
.'...' ,'. .m. m.a.. m .,m.i.
. _ . - . . ,.mn.
a.w m.a. ax.m. m. -. . ._ ,.. .._ ,.. i ., nm. .,, .u o s A = A e n, a, 7 ne_ _e_ s_ . a,a. -. a $..s-.aU.,m .In. ,_..._ Amena_. . ,.m,y.n1 n.n,
"r---'*
g I.'.%m.n.,m.l
. . . . .. ,m.a ,n.a.. m.en.e... .a.n.a. .wn
_,,,,,,,;,,,,,w, n, , r---~ . "- -
. ._,.m.,,.., - . . - . . m. .a.u. . m.
. . _.. i. m, .
in. ._. .. i.m.,.,. w en.. u_ ._ ., wit._ws G0mfW , - - - - - - - - -
.---m, s e.s . . A'8~ 1
. mssmi,,,, .u e.,
, heen 71 G- -'"i=---'-'----
,, m ,,, ,, . i m,,
/ Leo 4.8.MJ,
-e m.m,u. ._ ,, , e.u. .___.m. .-.-,.
. _n_ , .n. ,, . ,. n Of the te!::t!^n e~owof-at
,,,,,,,,m,,,,,,,,,,,,,,,,,,,,
.am.Awl
. _ a. e_ m. .,_ Sn.0,L. a_n, Inn. me. * *- - - - -
""7""
__... r----- m . m t ,'"m a1,,' m e ,s a ," g " M, .- * ".. m.....A..'.'..m..m..+.h.^.8._-..",
-ogan',',',',,,,','--"-
in. .e. m.a,._mn.
- -. ..m. enne.m.s. ,m.a n uA. .ig
'"""s'-r-I,
.. . . _ . a n.m.. _ f_a.ri.N.,.
. m H..,s _._
, ale ._a,m. . .m.a I..e t.oe ,
-__ .. . .k, .n. n. . n. 4. n. a_m_i.._e . . b 4._.
"ad8", ;a.a *ha
-- - ----- ed ht^^L.
fun"*!On of 2n ^> 't Of
& .e.n.a m. u. ..n. . .u.
. ,. m..-,.._m_
.. .___ _ , i .,. o u_ _ m. ,,.
,mmoonm ,mnemt ma m,wi, w
- - " ~ ' " " ' ' ' ~ ' " " " " " '
_on.a,t.-___... a,, tan. n,. . . . eu r-- - - le " A*Ad a" > s a^ m^= +h i -
,n. . .o_mi ... . im. m. .m.,. s. a.s. o. n.u, -. . emn.e.m. .wm.,m.,u,""'"-"'"'""
k N ,,,,
,#.,M , .R n.#.!1_. _. _ . _. ..,. M
. _ .kk#h
. _ . .A- ,M 8,# $. #.,,..G
,h _.
.e .in.n.i
-r----
mm. .. , m,m, I, tm , f SR 4 3 F.2 N -m
%haR 0 020 d^!*.2 '. Venfy the RM automebc bypass setpoint Me i to be > 20% RTP every 24 rnonths.
%_ s s
SR 4 3 F 3 N Venfying control rod sequences input to the RM are d g conformance with BPWs prior to dectanng RM o.m.a. :mn, .on.Q. OPERABLE following loading of sequence into RVWI. Amendment No. 39, 478 3/4.3-3
ATTACHMENT B LIMITING FONDITIONS FOR OPERATRON SURVEXLLANCE REQUXREMENTS 3.3 REACTIVITY CONTPOL (Cont) 4.3 PEACTIVITY CONTROL (Cont) A,i , F A2L M B. Control Rod B.
' cont ) OPERABILITY] ControlRodd(Cont) OPERABILITY l h~o33ph>] l Control rods shall not be 9 g[M Prior to control rod withdrawal withdrawn for startuplee l 'cr duringi J lrefEcTf Tiinless at least two (# 3 for startupherIfy~thIt lrcfucling, at least A, source range channels have an ,
two sour 8e range channels have observed count rate equal to or An' an observed count rate of at greater than three counts per least three counts per second. second. $ m m hy j Gr Thc 'TJi chall bc cpcrcbic cc 19'*"*G **'d' ' '"d' ' ' ' g_ rcquired F Tabic 3.2.C 1, or MTKWS-M. centrol rod w;thdrcuci c';11 bC y A. LCO 3.3 8.3 carmot te met. L 1 . _ L. -
""'"'~2 '
~ %
1 Pleon the mode snach m shutdown- hwnedutk C. Scram Insertion Times C. Scram Insertion Times l I 3 C )l. Average scram insertion time, for all operable control rods -
>]
~s Following each refueling outage, or after a reactor As from de-energization of the Ed3Cj shutdown that is greater than scram pilot valve solenoids to 120 days, each operable control dropout (DO) of notches 04, rod shall be subjected to scram As-24, 34, and 44 shall be no time tests from the fully greater than: withdrawn position. If testing Notch Average Scram is not accomplished with the i l'
Position Times (seconds) nuclear system pressure above 950 psig, the measured scram 44 DO 0.508 insertion time shall be 34 DO 1.252 extrapolated to reactor 24 DO 2.016 pressures above 950 psig using 04 DO 3.578 previously determined correlations. Testing of all operable control rods shall be completed prior to exceeding 40% rated thermal power. 1 i i l l
Ci!r 1 **
Amendment No.15, SS,124,139,165 3/4.3-4
ATTACHMENT B LJMITING CONDITIONS FOR OPERATIQN SERVERLLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REAR'TIVITY CONTROL C. Scram Insert ion Times (Cont) C. S_ cram Insertion Times
- 2. Average scram insertion time - Within each 120 days of for the three fastest operable -k>W b operation, a minimum of 10% of control rods in each group of IR43C2)
'S
~ ; the control rod drives, on a four control rods in all two- rotating basis, shall be scram by-two arrays from de- g tested as in,4.3.C.1. An energization of the scram evaluation shall be completed pilot valve solenoids to every 120 days of operation to dropout (DO) of notches 04, provide reasonable assurance 24, 34, and 44 shall be no As that proper performance is greater than: being maintained.
Notch Average Scram Position Times (seconds) 44 DO 0.538 i 34 DO 1.327 24 DO 2.137 04 DO 3.793 A' 4 D. ontrol Rod Accumulators
+r T': manimur arrar .na c r t ior. -v time for any operabic control Q4 3 D Once a shift, check the status of red frcr de encrg:rctic- of K the pressure and level alarms for the scram pilot ecl ec each accumulator.
b.. ncicac d to drorcut of " cts 0; ch^11 ;ct cncccd '.00 j ccccada, i APPLCABIL TY: 8 D. Control Rod Accumulators RUN and STARTUP MoOES; . REFUEL MODE uuhon the reactor vessel head h itAy 1.t cli rccctor cpcrc:ieg en==ned. -- -- 4 prcscurcs, a red accumulater mcy - - I u_ 2.-__.__u.s._ c . . . 2 _2.._u._,
-- ACTONS: Mg - 9
.~
.~r... s. .~
cther control red . thc mine rod ( Leo a s e cennoi to n i x , aquarc array Orctnd this rod haa \1 Be in hot SHUTDOWN ewhm 12 hours. ) e., N l w -Incpc rcbic accumulet-ee- j Er Dircctionci contrci eclec 4 Msart s ~ cicctrically dicarmcd ubilc in i LCO 3.3.D _, c :- fully incerted pca tion h Ccrcr inscrtion tinc grcatcr l than thr. monimum permincibic 1 Ao i 4ascrtics,tima l
)
If a contrc1 red ustS on !
.nopcrab1 accumulator is inscrted " full in" and :ta cirectic:.cl contrci calecs arc !
clectrically dicarmcd, it shal , act be considcrcd to hacc cn l n o p c r c b i c a c::u m u l a t e r I l t Revicion 186 Amendment No.-65,124,146A65 3/4.3-5
ATTACHMENT B LIMITING CONDITIONS FOR OPERATION SURVEIL 7.ANCE REQU3REMENTS 3.3 PEACTIVITY CONTROL (Cont) 4.3 PEACTIVITY CONTROL (Cont) A E. Reactivity Anomalles E. Reactivity Anomalles .. A,3 QCO3 ihe reactivity equivalent of g During [the atcrtup tcai progrc= l 4 the difference between the V lendjstartups fo71owlWg j Q actual critical rod
'4*
refueling outages, the critical ' m configuration and the expected - rod configurations will be Am osmy configuratiorfduring poucr ] compared to the expected i QN 4cperaticg 5hh11 yot exceed 1F configurations at selected ) Gk7 Lp Y H M I=IT-~I;cuccc5@ operating conditions. These ccncws ~th rcactor will be chut down comparisons will be used as a tu ,%
' until the causc Saa beer base data for reactivity I g , ,, , +dctcr-incd and cor ccti te monitoring during subsequent SHutDom j sccicnc havc bcc;. tchcr if such power operation throughout the )
E I~cct icr 7 crc appropriate,- fuel cycle. At specific power operating conditions, the 40 h -Ef Opccificat ion; 2. 2. " t.'rcugh critical rod configuration will 0 abovc caract bc ct, an be compared to the ordcrly rhutdcun shall bc configuration expected based 4e h4eted and the rccctor chc11 upon appropriately corrected bc i- the ccid Chutdcun past data. This comparison condition withir Scura, will be made at least every Ah a Cpecification; 2.2.A through D full power month. Ch'vc do not opply uhcr. thcr; j is ,c tuc1 1: the rcactor h ::ct I vcuccl. Occd] !A} G. Scram Discharce Volume G. Scram Discharae Volume _ gN 3 Scram d'ischarge volume
*~
'he scram discharge volume drain and vent valves; y
h'As ]0330)*operableNch5cr ] drain & vent valves shall be m5WL50.". Q3 0.9 p e r i Verif M open at least
- c rod i; -
once per month. V(0fi'~cp5cabiccontrol w;thdrawr - Testdas specified in Aa _ [ 43G2 h b l o M--any e f--t-he scram d.13. These valves may discharge volume drain or .. 4 be closed intermittently (ACTION A-~\ ' A is; ' vent valves er-e made or for testing under foundinoperable[.i.cr35iIy administrative control. 3?i5IT~bc >:itictcd y[0h&E5a ; jai r-i the rccctor shali [Ee+d-{ Shut 3own wiElii~fbe in 24 A] During each refueling interval verify the scram SR 4 3-Gg hours. discharge volume drain and vent valves: HO 12 IA,A 2 -[ s
- a. Close within 30 seconds after receipt of a N reactor scram signal end APPLICABILfTY RUN and STARTUP MoOE ^
REFUEL MOoE when the reactor b. Open when the seram is
- h"*d W " 9 reset.
A 9:&!cr in Amendment NO. 65, 4 49 3/4.3-6
- llH99ft tl BJ pontrol Rod Opirability .
. Insoft 2.
b ~ _ LCO 3 3 B 1 B Control Rod Oprability Each control rod chall be OPERABLE.
- SR 4.3 B 1.1 6EPLICABILITY:
RUN and STARTUP MODES; NOTE Not required to be performed until 7 days after REFUEL MODE when the reactor vessel the control rod is withdrawn and thermal power is head is fully tensioned. (See also 3.10.D-) greater than the LPSP of the RWM. ACTIONS' A. One withdrawn control rod stuck. Insert each fully withdrawn OPERABLE control rod at least one notch once per 7 days. NOTE Rod Worth Minimizer (RWM) may be SR 4 3 B.12 bypassed as allowed by LCO 3.3.F. NOTE 1 Venfy stuck control rod is Not required to be performed until 31 days after separated from other inoperable the control rod is withdrawn and thermal power is control rods by two or more greater than the LPSP of the RWM. OPERABLE control rods immediately. Insert each partially withdrawn OPERABLE lL[ ' AND control rod at least one notch once per 31 days. 2 Disarm the associated control rod drive (CRD) within 2 hours. 3 Perform SR 4.3.8.1.1 and SR 4.3.B.1.2 for each withdrawn OPERABLE control rod within 24 hours from discovery of Condition A concurrent with thermal power greater than the Low Power Setpoint(LPSP)of l the RWM. j AND 4 Venfy LCO 3.3.A.1 is met within 72 hours. AND
! 5 NOTE Not applicable when thermal power > 20 % RTP, Ensure stuck control rod is in l compliance with BPWS sequence I within 8 hours.
I Verify control rod drop accident ' limit of 280 cal /gm is not exceeded within 8 hours. B. Two or more withdrawn control rods stuck. 1 Be in HOT SHUTDOWN within I 12 hours.
. Isnemt 4I
' ~
(-- C. p NOTE Separate condition entry is allowed for fD. NOTE each control rod. Not appicable when thermal power
> 20% RTP, One or more control rods inoperable for reasons other than Condfbon A or 8. Two or more inoperable control rods not in
- c. .
compliance with banked position !.. n'
-g withdrawal sequence (BPWS) and not Rod Worth Mi imizer (RWM) may be bypassed as allowed by LCO tro r 3.3.F.
1 Restore compliance with BPWS Fully insert inoperable control rod '" " within 3 hours. O_B AND 2 Venfy control rod drop accident 2 Disarm the associated CRD within limit of 280 cal /gm is not exceeded 4 hours-wfthin 8 hours. O_R 3 Restore control rod (s) to OPERABLE status within 8 hours. i l I l linewe si i E. NOTE Not applicable when thermal power
> 20% RTP.
I One or more groups with four or more inoperable control rods. 1 Restore control rod (s) to OPERABLE status within 8 hours. 9
. Insert 7 '
IW$l
~
H. Rod Pattern Control F. Rod Worth Minimizer (RWM)
< LCO 3 3 H LCO 3 3 F IW All OPERABLE control rods shall comply with the The RWM shall be OPERABLE. requirements of the banked posibon withdrawal sequence (BPWS)
APPLICABILITY: APPLICABILITY: RUN and STARTUP MODES with reactor RUN and STARTUP MODES with reactor thermal power s 20 % RTP. thermal power s 20 % RTP. ACTIONS: ACTIONS: N C' A RWM inoperable dunng reactor startup. A. One or more OPERABLE control rods not 1 immediately suspend control rod in compliance with BPWS. movement except by scram. g NOTE 2.1 Immediately venfy by Rod Worth Minimizer (RWM) may administrative methods that be bypassed as allowed by LCO startup with RWM inoperable has ' not been performed in the last - [ 12 months. Move associated control rod (s) to correct postion within 8 hours. AND
, j q 2.2 Venfy movement of control rods 2 Venfy control rod drop accident \
g is in compliance with banked limit of 280 cal /gm is not position withdrawal sequence exceeded within 8 hours. (BPWS) by a second licensed OR operator or other qualified member of the technical staff g
\2 Declare associated control rod (s) noperable within 8 hours.
during control rod movement. B Rod worth minimizer (RWM) inoperable B. Nine or more OPERABLE control rods not during reactor shutdown. in compliance with BPWS. 1 Venfy movement of control rods 1 NOTE is in accordance with BPWS by a Rod Worth Minirnizer (RWM) may
\ second licensed operator or other be bypassed as allowed by LCO qualrfied member of the technical 3.3.F.
staff during control rod movement. Immediately suspend withdrawal of control rods. l AND 2 Place the reactor mode switch in the shutdown position within 1 hour. SR 4.3 H Verify all OPERABLE control rods comply with BPWS every 24 hours.
I f. (
. Insert 8 O. ControlRod Accumuletors LCO 3 3 0 l
Each control rod scram occumuletor tha8 be D. Two or rnore control rod accurrotetors l OPERABLE. Inoperable, concurrent with lose of APPLICABILITY: ) reactry steam dome pressure < 960 l
' RUN and STARTUP MODES; pe%
REFUEL MODE when the reactor veneel 1 Vertfy all control rode 1 assocented with inoperable , ACTIONS: accumulators are Mly NOTE s.,e,sie en e,,,y . a wed o, eacn inserted immediately. [ control rod scram accumulator. 2 Declare the assocated f control rode inoperable A. Controlrod scram accumuletor(s) ,
,,, inoperable with reactor steam dorne
' peseurs 2 960 %
% E. Required achon and assocated 1.1 Venfy no adjacent complebon trne of C.1 or D.1 not met OPERABLE controlrod has an inoperable scram i NOTE accumulator witNn Not applicable if all 1 hour. Inoperable control rod g scram occumulators are 1.2 Verify no adjacent control associated with fully rod is electrically desarmed inserted control rode.
In a non-Miy inserted poetion witNn 1 hour. Place the reactor mode 93 ewRch in the shutdown 2 Deciere the associated poeluon immedetely. control rod inoperable within 1 hour. 1 B. Controlrod scram accumulator (s) (noperable with reactor steam dome
' pressure < 950 poig or reactor thermal power s 20 % RTP.
1 Restore incporable accumulator to OPERABLE etetus within 8 hours. f 9B 2 Declare the sesociated control rod inoperable withm 8 hours. C. Two or more control rod accurnuistors inoperable, concurrent with loss of chargmg water pressure, when ruector steem dome preneure 2 960 poig. k 1 Restore chargmg water header pressure witNn 20 rmnutes M 2 Restore inoperable accumulator (s) to OPERABLE etstus wthin 8 hours.
5
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Attachment C Discussion of Changes
1 1 DISCUSSION OF CHANGES ATTACHMENT C i Section 3/4.3
. REACTIVITY CONTROL ;
ADMINISTRATIVE CHANGES ; . A, This change proposes to delete the generic Applicability and Objective sections of Current Technical Specifications (CTS) 3/4.3. The current wording does not provide any technical information (either actual or interpretational) necessary for plant operators, as well as other users, to understand or implement the requirements of the Technical Specifications. The generic Applicability will be replaced with specific APPLICABILITY for each Limiting Condition for Operation (LCO). Since this change will result in no technical changes (either actual or interpretational), it is considered administrative. A2 These changes propose editorial rewording (either adding or deleting) which result in no technical changes (either actual or interpretational) to the Technical Specifications. Therefore, they are considered administrative. As These proposed changes are considered human factor improvements to existing requirements as follows: (1) Each LCO will have its own unique alpha numeric identifier. (2) Each surveillance will have its own unique alpha numeric identifier. (3) Each LCO will have its own APPLICABILITY statement. l I (4) Each LCO will have all ACTIONS necessary to satisfy the LCO. ! These changes only affect the format in which the requirements are presented, not the technical content of the requirements. Since these changes will result in no technical changes (either actual or interpretational), they are considered administrative. A4 CTS 3.3.F states, " Specifications 3.3.A through D above do not apply when there is no fuel in the reactor vessel". This requirement is restated "At all times when there is fuel in the reactor vessel", as the APPLICABILITY for new LCO 3.3.A.1. In addition, CTS 3.3.F requires, "If Specification 3.3.A through D above cannot be met, an orderly shutdown will be initiated and the reactor shall be in Cold Shutdown condition within 24 hours". This requirement is restated as ACTIONS A. "LCO 3.3.B.2 cannot be met" and required ACTION A.1, "Be in COLD SHUTDOWN within 24 hours" for new LCO 3.3.B.2. As This proposed change will delete that portion of existing surveillance 4.3.A.2 that provides instructions for when the surveillance is not required. The requirements for when the surveillance is required are clear. It is understood that if the condition initially requiring the surveillance is no longer applicable, then the surveillance is not required. Therefore, this proposed change is considered administrative. 3/4.3 DOC 1
l DISCUSSION OF CHANGES ATTACHMENT C Srction 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued) As This change proposes to replace CTS 3.3.A.2.b with proposed LCO 3.3.B.1, ACTIONS A.2 and C.2 and to delete that portion of CTS 3.3.A.2.b that provides details of the methods for disarming control rod drives (CRDs). The methods for disarming control rod drives (CRDs) are addressed in the current BASES and will be carried forward into the revised BASES. The requirement of CTS 3.3.A.2.b to disarm an inoperable control rod is retained in proposed LCO 3.3.B.1, ACTIONS A.2 and C.2. Also, CTS 3.3.A.2.b does not specify a time for completing this ACTION. Proposed ACTION A.2 will allow 2 hours to disarm an inoperable control rod that is stuck and ACTIONS C.1 and C.2 will allow 4 hours to insert and disarm all other inoperable control rods. These times recognize the actual operational steps involved to fully insert and/or disarm an inoperable conirol rod following discovery of the inoperable condition. Since the current requirements continue to be maintained, this change is considered administrative. The requirement of CTS 3.3.A.2.b to ensure Reactivity Margin (Specification 3.3.A.1) will be carried forward in proposed LCO 3.3.B.1, ACTION A.4 for a stuck control rod. For all other cases of inoperable control rods, proposed LCO 3.3 B.1 ACTIONS C.1 and C.2 will require them to be fully inserted and disarmed. This will ensure that the inoperable rod is in a position to satisfy reactivity margin. Since the current requirements will continue to be maintained, this change is considered administrative. A note is added (at the start of ACTIONS C), " Separate condition entry is allowed for each control rod", to provide direction consistent with the intent of the required ACTIONS for inoperable control rods. The required ACTIONS for each condition provide appropriate compensatory actions for each inoperable control rod. Complying with the required ACTIONS may allow for continued operation, and subsequent inoperable control rods are governed by subsequent condition entry and application of associated required ACTIONS. Required ACTION C.1 is modified by a note, which allows the RWM to be bypassed, if required, to allow insertion of the inoperable control rods and continued operation. LCO 3.3.F provides additional requirements when the RWM is bypassed to ensure compliance with the control rod drop accident (CRDA) analysis. The addition of these notes serve to assist the operator in complying with the required ACTIONS and do not alter the intent. Therefore, these proposed changes are considered administrative. 3/4.3 DOC 2 L- . . __ __ l
J DISCUSSION OF CHANGES ATTACHMENT C I Srction 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued) A7 CTS 3.3.A.2.e specifies that the number of inoperable control rods shall not exceea eight and that Specification 3.3 A.1 (Reactivity Margin - Core Loading) must be met at all times. The requirement to have no more than eight inoperable control rods is carried forward in proposed LCO 3.3.B.1, ACTION F. The requirement to ensure reactivity margin (CTS 3.3.A.1) will be carried forward in proposed LCO 3.3.B.1, ACTION A.4 for a stuck control rod. For all other cases of inoperable control rods, proposed LCO 3.3 B.1 ACTIONS C.1 and C.2 will require them to be fully inserted and disarmed, which will ensure that the inoperable rod is in a position to satisfy the reactivity margin. Since the current i requirements will continue to be maintained, this change is considered administrative. 1 As CTS 3.3.B.1 requires each control rod to be coupled to its drive or completely inserted, and to electrically disarm the control rod directional control valves. The requirement that control rods be coupled to their drive mechanism is presented in proposed SR 4.3.B.1.3, making it a requirement for control rods to be considered OPERABLE. The actions to fully insert inoperable control rods and ) disarm them are presented in proposed LCO 3.3.B.1 ACTIONS C.1 and C.2. l Elimineting the existing specification for control rod coupling, by moving it to another specification (as a Surveillance Requirement), does not eliminate any requirements, or impose a new or different treatment of the requirements. l Therefore, this proposed change is considered administrative. '
- CTS 3.3.B.1 also exempts control rod coupling requirements when in the refuel condition with the reactor vented and allows two control rods to be removed as long as Specification 3.3.A.1 (Reactivity Margin) is met. CTS 3/4.10.D also specifies requirements for multiple control rod removal during core alterations (the refuel condition with the reactor vented). The requirements of 3/4.10.D also ensure that Reactivity Margin requirements are met. This proposed change will ,
delete the reference to when control rod coupling is not required and propose revising the APPLICABILITY for proposed LCO 3.3.B.1 to reference CTS LCO 3.10.D " Multiple Control Rod Removal". This proposed change does not eliminate any requirements or impose a new or different treatment of the requirements. Therefore, this proposed change is considered administrative. As CTS 3.3.B.2 exempts requirements for the control rod housing support system to be in place if all control rods are fully inserted and Specification 3.3.A.1 is met. This ACTION is being replaced with requirements to be in cold shutdown within 24 hours as described in Discussion of Changes A4 . This will ensure the requirement for all control rods to be inserted and Specification 3.3.A.1 are met. This proposed change does not eliminate any requirements or impose a new or different treatment of the requirements. Therefore, this proposed change is considered administrative. 3/4.3 DOC 3
DISCUSSION OF CHANGES ATTACHMENT C S:ction 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued) Ao i CTS 4.3.B.3 requires the Rod Worth Minimizer (RWM) be verified OPERABLE prior to control rod withdrawal for startup or insertion to reduce power below 20% and specifies the details (a, b, c, and d) for performing this verification. Proposed SR 4.3 F.1 will require performance of an INSTRUMENT FUNCTIONAL TEST of the RWM prior to control rod withdrawal for startup or insertion to reduce power below 20%. The specific details, except for (a) verification of sequence input, for performing this test are relocated to the BASES. Since the original intent of the surveillance (i.e., to verify operability) is carried forward by requiring a functional test, this change is considered administrative. For discussion of change to CTS 4.3.B.3.a, verification of sequence input, see Discussion of Change L7. Asi CTS 3.3.B.4 and SR 4.3.B.5 specify the count rate requirements for the Source Range Monitors (SRMs) during refueling. CTS 3/4.10.B also specifies the operability requirements, including count rate for the SRMs during core alterations (refueling). The requirement to have greater than 3 counts per second is stated in both specifications. This proposed change will delete the reference to refueling in proposed LCO 3.3.B.3 and SR 4.3.B.3. Deleting the reference to refueling does not eliminate any requirements, or impose a new or different treatment of the requirements. Since the current requirements will continue to be maintained, this change is considered administrative. Au CTS 3.3.B.5 specifies the requirements for the Rod Block Monitor (RBM) as required by Table 3.2.C-1. CTS 3/4.2.C " Control Rod Block Actuation" also states the limiting conditions for operation for the instrumentation that initiates l control rod block are given in Table 3.2.C-1. Table 3.2.C-1 specifies the l APPLICABILITY for the RBM. The notes for Table 3.2.C-1 remain unchanged in the proposal and specifies the ACTIONS for an inoperable RBM. Table 4.2.C specifies the surveillance requirements for the RBM. This proposed change will l delete CTS 3.3.B.5. Deleting CTS 3.3.B.5 will eliminate confusion without eliminating any surveillance requirements, or imposing any new or different treatment of the requirements. Since the current requirements will continue to be maintained, this change is considered administrative. A 33 CTS 4.3.E still contains requirements for the startup test program. The startup test program was performed following initial fuel loading to demonstrate that the station was capable of operating safely and satisfactorily. This change deletes the reference to the startup test program which is no longer applicable. Au CTS 3.3.G.1 requires the scram discharge volume drain and vent valves to be OPERABLE whenever more than one OPERABLE control rod is withdrawn. Since the control rods can only be withdrawn in the RUN, STARTUP and i REFUEL MODES proposed LCO 3.3.G requires APPLICABILITY only in the RUN and STARTUP MODES, or REFUEL MODE when the reactor vessel head is fully tensioned. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling conditions. Since the requirements have not changed, this is considered an administrative change. 3/4.3 DOC 4
l DISCUSSION OF CHANGES ATTACHMENT C j S::ction 3/4.3 REACTIVITY CONTROL l ADMINISTRATIVE CHANGES (continued) Asi CTS 4.3.G.1.b. specifies testing of the scram discharge volume vent and drain valves in accordance with CTS 3.13. The requirements for surveillance testing per the Inservice Test Program are contained in CTS 4.13. This change will provide the correct reference to the applicable CTS without eliminating any requirements, or imposing any new or different treatment of the requirements. Since the current requirements will continue to be maintained, this change is considered administrative. l l l 3/4.3 DOC 5
DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE M, CTS 3.3.F allows a completion time of 24 hours to reach COLD SHUTDOWN if the CTS 3.3.A through D cannot be met. The following more restrictive requirements are proposed: Proposed LCO 3.3.B.1, required ACTIONS B.1 and F.1, reduces the completion time to 12 hours to reach HOT SHUTDOWN if the requirements for control rod operability cannot be met. This change is more restrictive because all rods must be fully inserted in 12 hours instead of the currently required 24 hours. Proposed LCO 3.3.B.3, required ACTION A.1, will require placing the mode switch in shutdown immediately if SRM count rate is < 3 counts /second prior to startup. This change is more restrictive because the mode switch must be placed in shutdown immediately instead of the currently required 24 hours. I LCO 3.3.C, required ACTION A.1, reduces the completion time to 12 hours to reach HOT SHUTDOWN if the requirements for control rod scram times cannot be met. This change is more restrictive because all I rods must be fully inserted in 12 hours instead of the currently required 24 hours. These proposed changes are more appropriate because once the control rods are fully inserted they have fulfilled their reactivity control requirements. Cooling I the unit down (proceeding from HOT SHUTDOWN to COLD SHUTDOWN) does j not provide any additional safety margin and, in some cases, could be counter i productive since positive reactivity is inserted during a cooldown. M2 This proposed change will delete the allowance to not consider control rods that are fully inserted and electrically disarmed inoperable (CTS 3.3.A.2.c). The control rod drop accident evaluation (NEDE-24011-P-A-11-US) assumes that the l plant is being operated within the constraints of the banked position withdrawal l sequence (BPWS). "NEDO-21231, Banked Position Withdrawal Sequence (BPWS)" requires all inoperable control rods capable of insertion to be fully inserted and disarmed when operating with reactor thermal power s; 20 % RTP. Proposed LCO 3.3.B.1, ACTION C, will require control rods capable of insertion (not stuck) to be fully inserted and disarmed once they have been declared inoperable regardless of reactor thermal power. Therefore, this is considered a more restrictive requirement. 1 3/4.3 DOC 6
DISCUSSION OF CHANGES ATTACHMENT C Stction 3/4.3 REACTIVITY CONTROL i TECHNICAL CHANGES - MORE RESTRICTIVE (continued) M3 This proposed change will delete the requirements for control rod position indication from Tables 3.2.F and 4.2.F and add surveillance requirement SR 4.3.B.1.5. CTS Table 3.2.F requires control rod position indication to be OPERABLE and CTS Table 4.2.F requires an Instrument Check of the control rod position once per shift. CTS Actions for inoperable control rod position (Notes for Table 3.2.F) allow continued operation with no control rod position indication in the control room for 7 days before requiring a plant shutdown. Proposed SR 4.3.B.1.5 will require determination of control rod position only once per 24 hours which is less restrictive, however, if position indication is lost for a control rod then it must be considered inoperable, fully inserted, and disarmed. "NEDO-21231, Banked Pc "on Withdrawal Sequence (BPWS)" requires control rods to be fully insert o and disarmed when operating with reactor thermal power s 20 % RTP if tneir position can not be determined. Although control rod position may now be determined by the use of OPERABLE position indicators, by moving control rods to a position with an OPERABLE indicator, or by the use of other appropriate methods, if 9 or more control positions cannot be determined, the reactor must be brought to the HOT SHUTDOWN MODE. Therefore, this is considered a more restrictive requirement. j M4 Proposed LCO 3.3.B.1, ACTION D, addresses the condition when the reactor is s 20% Reactor Thermal Power (RTP) and two or more inoperable control rods are not in compliance with the Banked Position Withdrawal Sequence (BPWS), and are not separated by two or more OPERABLE control rods. The required ACTION is to restore compliance with the BPWS within 8 hours, verify control rod drop accident limit of 280 cal /gm is met within 8 hours, or restore the control rod to OPERABLE status within 8 hours. The control rod drop accident evaluation (NEDE-24011-P-A-11-US) assumes that the plant is being operated within the constraints of the banked position withdrawal sequence (BPWS).
"NEDO-21231, Banked Position Withdrawal Sequence (BPWS)" requires all inoperable control rods be separated by two OPERABLE control rods when operating with reactor thermal power s 20 % RTP. Deviations from the BPWS may also be acceptable provided they do not create incremental rod worth which l would result in peak fuel enthalpy energies > 280 cel/gm. CTS does not stipulate any such restrictions. Therefore, this is considered a more restrictive change.
A Note limits this requirement to 5 20% Rated Thermal Power (RTP) because analysis has shown that it is impossible to obtain a rod worth high enou0h to produce a peak fuel enthalpy of 280 cal /gm above 20 % RTP. 3/4.3 DOC 7
DISCUSSION OF CHANGES ATTACHMENT C S:ction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) Ms ' CTS 3.3.A.2.d requires control rods be declared inoperable if they have scram taes greater than that permitted by CTS 3.3.C.3. The maximum insertion time requirement for control rods to be considered OPERABLE is moved to proposed Sit 4.3.B.1.4. If the requirements of the surveillance cannot be met, the control ro:1 is inoperable. Moving the requirement to another Specification (as a A rveillance Requirement) does not eliminate or impose a new or different tre atment of the requirements. CTS 3.3.A.2.d also allows a control rod with scram times greater than those permitted by CTS 3.3.C.3 (7 seconds) to remain at their current position and does not require them to be disarmed. This proposed change will require control rods with scram times greater than those permitted by CTS 3.3.C.3 be fully inserted and disarmed within 4 hours. Since this proposed change will not allow continued operation with control rods having scram times greater than 7 seconds, CTS 3.3.A.2.f is deleted. Me in addition to the limiting the total number of inoperable control rods, "NEDO. 21231, Banked Position Withdrawal Sequence (BPWS)" also assumes that there are no more than three inoperable control rods in any one BPWS group. Proposed LCO 3.3.B.1, ACTION E, will ensure that this requirement is met. Since the BPWS is not required to be followed when thermal power is
> 20% RTP, required ACTION E.1 is modified by a note indicating that the condition is not applicable > 20 % RTP. The allowed completion time of 8 hours considers the low probability of a CRDA occurring during this short period of time. The addition of a new requirement is a more restrictive change.
M7 CTS SR 4.3.B.I.b requires that rod coupling be verified "when the rod is fully withdrawn the first time after each refueling outage." The proposed SR 4.3.B.1.3 j requires this coupling check each time the rod is fully withdrawn. Therefore, this 1 change is more restrictive. 3/4.3 DOC 8
DISCUSSION OF CHANGES ATTACHMENT C Srction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGCS - MORE RESTRICTIVE (continued) Ms CTS 3.3.B.3.b requires control rod pattems and the sequence of withdrawal or insertion be established to ensure maximum rod worth is not exceeded. If the requirements of CTS '3.3.B.3 cannot be met, CTS 3.3.F requires an orderly shutdown be initiated and the plant brought to COLD SHUTDOWN within 24 hours. Under these conditions, the reactivity worth of an individual control rod could be in excess of that necessary to insert a peak enthalpy >280 cal / gram when the consequences of a control rod drop accident are most severe. Proposed LCO 3.3.H, " Rod Pattern Control'* will replace CTS 3.3.B.3.b with an appropriate LCO, APPLICABILITY, ACTIONS, and Surveillance Requirements ' that are consistent with the assumptions of NEDO 21231," Banked Position Withdrawal Sequence", Section 7.2, January 1977 PNPS is a BPWS plant as described in NEDE-24011-P-A, " General Electric btandard Application for Reactor Fuel", Section S.2.2.3.1. Compliance with BPWS, limits maximum rod worth such that fuel enthalpy addition due to CRDA will not exceed 280 cal /gm 4 fuel enthalpy. The proposed required ACTIONS will (A.1) ensure that out-of-sequence OPERABLE control rods are returned to their required positions within 8 hours, or (A.2) an analysis will be performed within 8 hours to ensure that the current positions do not create maximum incremental rod worth that would cause the CRDA limit of 280 cal /gm to be exceeded, or (A.3) the control rods will be declared inoperable within 8 hours. The 8 hour allowance is consistent with allowed actions described in NEDO-21231. The probability of a CRDA occurring during this short period is low, if a significant number of OPERABLE control rods (>8) are not in compliance with BPWS attempting to correct the out-of-sequence condition, especially if it requires withdrawing control rods, could worsen the situation. Therefore, actions are required to suspend control rod withdrawal immediately and place the mode switch in the shutdown position if the number of OPERABLE out-of-sequence control rods cannot be reduced to < 9 within 1 hour. CTS does not prescribe any completion times for determining and/or correcting out-of-sequence conditions. Therefore, the addition of required ACTIONS and completion times is considered a more restrictive change. ; I 3/4.3 DOC 9 l
1 DISCUSSION OF CHANGES ATTACHMENT C Soction 3/4.3 F.EACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) Me This proposed change adds a new surveillance requirement (SR 4.3.F.2) for verifying that the RWM is not bypassed when reactor thermal power is s 20% every 24 months. The RWM is automatically bypassed when power is above a specified value. The power level is determined from feedwater flow and steam flow signals. The automatic bypass setpoint must be verified periodically to be
> 20% RTP. The frequency takes into consideration the plant conditions required to perform the test and is intended to be consistent with a fuel cycle length of 24 months.
Mw CTS 3.3.D allows an unspecified number of control rod accumulators to be inoperable as long as no other control rod in the nine-rod square array around this rod has a: (1) Inoperable accumulator, (2) directional control valve electrically disarmed while in a non-fully inserted position, or (3) scram insertion time creater than the maximum permissible insertion time. In addition, if the ! control rod is inserted " full-in" and its directional control valves are electrically disarmed, it need not be considered to have an inoperable accumulator and the l separation criteria would not have to be applied. l The proposed changes will impose more restrictive requirements as follows; l With reactor steam dome pressure :t 950 psig, proposed LCO 3.3.D, ACTION A will continGe to allow operation with multiple inoperable accumulators provided there are no adjacent OPERABLE control rods with inoperable accumulators (required ACTION A.1.1) and there are no adjacent control rods disarmed while in a non-fully inserted position (required ACTION A.1.2) or the control rod associated with the inoperable accumulator (s) must be declared inoperable (required ACTION A.2). Startup test results, as described in NEDO-20252, "STARTUP TEST RESULTS, PILGRIM NUCLEAR POWER STATION, UNIT 1", February 1974, show that the difference between the mean scram times for normal accumulator charging pressure with reactor pressure = 800 psig and accumulator pressure O psig with reactor pressure = 950 psig, was insignificant (0.04 sec on average) for the 4 slowest control rods. With reactor steam dome pressure < 950 psig or reactor thermal power s 20 % RTP, proposed LCO 3.3.D, ACTION B, will require control rods with
-inoperable accumulators that cannot be restored to OPERABLE status within the specified time to be declared inoperable. With reactor steam dome pressure
< 950 psig, the contribution to control rod scram time from the accumulator becomes more important. However, at any reactor pressure, the control rod will scram even without the associated accumulator, although probably not within the required scram times. Therefore, providing this short time (8 hours) to restore the accumulator to OPERABLE status does not significantly increase the risk of an ATWS event.
l The CRDA evaluation (NEDE-24011-P-A-11-US) assumes that the plant is being operated within the constraints of the banked position withdrawal sequence (BPWS). "NEDO-21231, Banked Position Withdrawal 3/4.3 DOC 10
DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) Mw . Sequence (BPWS)" requires all inoperable accumulators to be restored to (continued) OPERABLE status within 8 hours or declare the associated control rod inoperable when operating with reactor thermal power s 20 % RTP.
- Loss of charging water pressure could cause multiple accumulators to become inoperable resulting in severe degradation of scram performance. In addition, should the loss of charging water pressure be the result of a loss of control rod drive pump, the control rods can no longer be inserted with normal drive pressure and cooling water to the drives will be lost. Proposed ACTION C addresses the situation where multiple accumulators may be repidly becoming l inoperable due to loss of charging pressure when reactor pressure is 2 950 psig.
Required ACTION C.1 addresses the need to restore charging water as soon as possible (within 20 minutes). If restoration of charging water pressure does not restore the accumulators to OPERABLE status, required ACTION C.2 provides additional time (8 hours) to restore the accumulators to OPERABLE status. This allowance provides a reasonable time to attempt investigation and restoration of the inoperable accumulators considering that reactor pressure is adequate to ensure the scram function of the control rods with inoperable accumulators. Proposed ACTION D addresses the situation where additional accumulators may be rapidly becoming inoperable due to a loss of charging pressure and allows any number of accumulators to be inoperable for up to 1 hour when reactor pressure is < 950 psig provided the associated control rods are verified to be fully inserted immediately. Provided all control rods with inoperable accumulators are fully inserted, this 1 hour allowance provides a reasonable time to attempt investigation and restoration of the inoperable accumulators. Proposed ACTION E ensures the reactor is returned to a condition in which the LCO does not apply when required actions to restore accumulator operability is not successful. If adequate charging pressure can not be restored within 20 minutes when reactor pressure is 2 950 psig, or all control rods with inoperable accumulators are not fully inserted when reactor pressure is < 950 psig, an immediate scram is required. This ensures that the extensions of ACTION C and D will not be used unless adequate CRD pressure is available to scram the reactor. A proposed Note at the beginning of the ACTIONS (" Separate Condition entry is allowed for each control rod scram accumulator") provides more explicit instructions for proper application of the new ACTIONS for Technical Specification compliance. Upon discovery of an inoperable accumulator, it is intended that each specific ACTION be applied regardless of its having been applied previously for other inoperable accumulators. This note is provided since more than one accumulator is allowed to be inoperable without requiring an immediate declaration of control rod inoperability. 3/4.3 DOC 11
l DISCUSSION OF CHANGES ATTACHMENT C Soction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued) M ii CTS 3.; E requires the reactor to be shut down if the reactrvity anomaly limit is ) exceedeu without specifying a completion time. Proposed LCO 3.3.E required ) ACTION A.1 will specify a completion time of 12 hours to reach HOT ' SHUTDOWN. This change is more restrictive because all rods must be fully inserted in 12 hours instead of the currently assumed 24 hours. M 12 CTS 3.3.G requires the reactor to be in COLD SHUTDOWN within 24 hours if any of the scram discharge volume drain or vent valves are made or found inoperable. Proposed LCO 3.3.G required ACTION A.1 reduces the completion time to 12 hours to reach HOT SHUTDOWN. This change is more restrictive because all rods must be fully inserted in 12 hours instead of the currently required 24 hours. Cooling the unit down (proceeding from HOT SHUTDOWN to COLD SHUTDOWN) does not provide any additional margin and, in some cases, could be counter productive since positive reactivity is inserted during a cooldown. l l l l t 3/4.3 DOC 12 l
- i. j
DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - RELOCATIONS R, CTS 3.3.C.3 provides a discussion of how to determine maximum scram insertion time. This change proposes to relocate details of the methods for timing control rod drives (CRDs) to the BASES for SR 4.3.B.1.4. The requirement to verify scram time is incorporated into proposed SR 4.3.B.1.4, therefore, it does not eliminate any requirements, or impose a new or different treatment of the requirements. Changes to these details will be controlled as described in 5.5.6. Technical Specification (TS) Bases Control Program. l l 1 l I 3/4.3 DOC 13
DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE Li CTS 3.3.A.2.a requires control rods that cannot be moved with control rod drive or scram pressure be considered inoperable and that the reactor be brought to a shutdown condition within 48 hours unless investigation demonstrates that the cause of the failure is not due to a failed control rod drive mechanism collet housing. This proposed change will allow continued operation with one withdrawn control rod that cannot be moved with control rod drive or scram pressure (stuck rod) regardless of the reason for it being stuck (proposed LCO 3.3.B.1, ACTIONS A). Therefore, this change is considered less restrictive. Continued operation with one stuck control rod is contingent upon (1) verification that the separation criteria is met (required ACTION A.1), (2) the stuck rod is disarmed (required ACTION A.2), (3) all OPERABLE control rods are exercised to ensure there are no other stuck rods (required ACTION A.3), and (4) Reactivity Margin requirements are satisfied (required ACTION A.4). When operating at s 20 % RTP, an additional requirement (A.5) to verify compliance with BPWS sequence or perform an analysis within 8 hours to ensure tid the current positions do not create maximum incremental rod worth that would cause the CRDA limit of 280 cal /gm to be exceeded is imposed. NEDO-21231, " Banked Position Withdrawal Sequence", Section 7.2, January 1977, does not permit operation within the BPWS range while a stuck control rod exists unless analysis exists to support such operation. The existing limitation of CTS 3.3.A.2.a for investigating the reason for the failure to insert (e.g., failed collet housing)is being omitted. The requirement to determine the stuck condition was not due to collet housing failure was added to the PNPS TS in Amendment 14, February 3,1976, because of circumferential cracks resulting from stress assisted intergranular corrosion occurring in the collet housings of drives at several plants. The purpose of this amendment was to ensure that the reactor would not be operated with a large number of control rods with failed collet housings. The proposed ACTIONS will only allow continued operation with one stuck control rod, provided that all withdrawn control rods are tested within 24 hours to confirm no additional stuck control rods exist. The failure of a single control rod to insert (scram) will not prevent the reactor from reaching a subcritical condition. A completion time of 72 hours is allowed for ensuring reactivity margin requirements are met. CTS does not specify a completion time which could be interpreted to be within 24 hours consistent with CTS 3.3.F. The 72 hour completion time is considered appropriate because of the actions necessary to perform the analysis, and even with one control rod stuck in a withdrawn position, the remaining OPERABLE control rods will scram and provide the required shutdown reactivity. 3/4.3 DOC 14
DISCUSSION OF CHANGES ATTACHMENT C Ssetion 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE Li A completion time of 8 hours is allowed for ensuring compliance with BPWS (continued) sequence or perform a rod worth analysis when s 20 % RTP. The 8 hours completion time is considered appropriate because of the limited number of allowed out-of-sequence control rods, the low probability of a CRDA occurring during the time the control rods are out-of-sequence, and is consistent with other corrective actions required by NEDO-21231. A Note is added to ACTION "A" that allows for bypassing the RWM in order to , fulfill the required ACTIONS A.3 and A.5, provided the proper ACTIONS of j proposed LCO 3.3.F (RWM) are taken. This is a human factors consideration to j ensure clarity of the requirement and allowance. I L2 CTS 4.3.A.2 requires that all partially or fully withdrawn control rods be exercised ! at least once per week. This SR could be satisfied by control rod withdrawal. However, it is possible for a control rod binding mechanism to exist that only i prevents control rod insertion. In such a case, a withdrawal test will not detect ' the problem. Therefore, proposed SRs 4.3.B.1.1 and 4.3.B.1.2 require control rods be inserted in lieu of the CTS requirement for " exercising". Since the purpose of the test is to ensure scram insertion capability, restricting the test to only allow control rod insertion increases the sensitivity of this test for detecting a problem that impacts this capability. The proposed requirements SR 4.3.B.1.1 and SR 4.3.B.1.2 will differentiate between fully and partially withdrawn rods. Fully withdrawn rods will still be inserted one notch once per 7 days. However, partially withdrawn rods will be i inserted one notch once per 31 days. The rational for decreasing the frequency ) of exercising partially withdrawn rods from 7 to 31 days is that partially withdrawn control rods have a significantly greater impact on core flux distribution than do fully withdrawn control rods. Power reductions may be required each week to perform this test on the partially withdrawn control rods. This potential impact on plant capacity is deemed excessive given the following considerations: I
- 1) At full power, a large percentage of control rods (typically 80-90%) are fully withdrawn and would continue to be exercised each week. This represents a significant sample size when looking for an unexpected random event.
- 2) Operating experience has shown " stuck" control rods to be a rare event while operating.
- 3) Partially withdrawn control rods are exercised during plant operations to maintain reactor power level. Should a stuck rod be discovered, all of the remaining control rods (even partially withdrawn) must be exercised within 24 hours (proposed LCO 3.3.B.1, ACTION A.3).
3/4.3 DOC 15
DISCUSSION OF CHANGES ATTACHMENT C SG;ction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) L3 CTS 4.3.A.2 requires all OPERABLE control rods be exercised once every 24 hours if reactor operation continues with three or more inoperable control rods. The originalintent of this requirement was to ensure the reliability of the remaining OPERABLE control rods if power operations were to continue with three or more not fully inserted, inoperable control rods. If the inoperable control rods were fully inserted and disarmed, they would not be considered inoperable (CTS 3.3.A.2.c) and the increased surveillance frequency would not apply. The proposed requirement for control rods that are inoperable but not stuck (LCO 3.3.8.1, ACTION C) is to fully insert and disarm the inoperable rod (s). Since continued power operation with not-fully inserted, inoperable control rods will not be allowed, there will be no requirement to exercise the OPERABLE rods to verify their operability other than the scheduled surveillance requirements in proposed SR 4.3.B.1.1 and SR 4.3.B.1.2. CTS 4.3.A.2 also requires all OPERABLE co,1 trol rods be exercised once every 24 hours if reactor operation continues with a stuck control rod for which CRD mechanism failure has not been ruled out. For a stuck control rod, regardless of the reason, the proposed requirement will require all OPERABLE rods be inserted at least one notch within 24 hours. This will verify the stuck control rod is not caused by a generic failure that would interfere with scram capability. Thereafter, continued testing of control rods will be at the normal frequency. Operating experience has shown stuck control rods to be a rare event during power operations. L4 in addition to verifying that the drive does not go to overtravel, CTS 4.3.B.1 also requires observance of a discernible response of the nuclear instrumentation when a control rod is withdrawn the first time following a refueling outage or after maintenance has been conducted. An indication of a flux level change on nuclear instruments demonstrates control rod motion out does not demonstrate that a control rod is coupled as is the intent of existing requirement 4.3.B.I.a. Therefore, this requirement is deleted. L5 CTS 4.3.B.1 requires observation that the control rod does not go to the overtravel position after maintenance without specifying the type of maintenance.
- The proposed SR 4.3.B.1.3 will only require observing the control rod does not go to the overtravel position after maintenance that could affect coupling integrity. Since the purpose of the surveillance is to determine that the control rod is coupled, restricting the performance to maintenance that could affect coupling integrity is appropriate.
l 3/4.3 DOC 16
DISCUSSION OF CHANGES ATTACHMENT C Srction 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) Le CTS 3.3.B.3.a does not allow control rods to be moved when the reactor is below 20% rated power, except to shutdown the reactor, unless the RWM is OPERABLE. A maximum of two rods may be moved below 20% design power when the RWM is inoperable if all other rods except those which cannot be moved with control rod drive pressure are fully inserted. Proposed LCO 3.3.F, " Rod Worth Minimizer", will continue to require operability of the RWM below 20% of design power, however, the requirements on control - rod movement are being relaxed. Proposed LCO 3.3.F, ACTION A, will still require suspension of control rod movement when the RWM is inoperable during startup unless withdrawal has not been performed with the RWM inoperable in the 12 months, and a second licensed operator or other qualified member of the technical staff verifies movement of control rods is in compliance with the banked position withdrawal sequence (BPWS). The RWM function assists and supplements the operator with an effective backup control rod monitoring routine that enforces adherence to established startup, shutdown, and low power level control rod procedures. Allowing a second licensed operator or other qualified member of the technical staff to verify the control rod movement is in compliance with BPWS which also provides effective control. Not allowing more than one startup per 12 months will ensure that the RWM is maintained OPERABLE. Although CTS 3.3.B.3.a allows control rod movement to shutdown the reactor without any constraints, proposed LCO 3.3.F. ACTION B, will also require a second licensed operator or other qualified member of the technical staff to verify movement of control rods is in compliance with BPWS. L7 CTS 4.3.B.3.a requires verifying the control rod withdrawal sequence input to the RWM computer prior to control rod withdrawal for startup and prior to insertion to reduce power below 20%. This verification is required for each plant startup and shutdown. Proposed SR 4.3.F.3 will require this verification only once following loading of the sequence into the RWM computer. The potential for error occurs when the sequence is initially loaded into the computer. Once the rod withdrawal sequence is verified, controls are in place to ensure that changes cannot be made without prior approval. Any change would require reverification. 3/4.3 DOC 17
1 DISCUSSION OF CHANGES ATTACHMENT C Section 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) La CTS 3.3.F states that " Specifications 3.3.A through D above do not apply when there is no fuel in the reactor vessel". This implies that Specifications A through D it ust be met during all MODES of operation when there is fuel in the reactor vessel. In the HOT SHUTDOWN and COLD SHUTDOWN MODES, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod OPERABILITY during these conditions. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling conditions. Therefore, proposed LCO 3.3.B.1 is revised to require APPLICABILITY only in the RUN and STARTUP MODES, or REFUEL MODE when the reactor vessel head is fully tensioned. Since control rod scram times and control rod scram accumulators are conditions for control rod operability, LCOs 3.3.C and 3.3.D are also revised accordingly. In addition, there are no design bases accidents (DBAs) or abnormal operational transients (AOTs) identified for conditions when one or less control rods are withdrawn that l require a scram. Because the proposed changes do not require APPLICABILITY in all MODES, they are less restrictive. Le CTS 3.3.E requires the reactivity equivalent of the difference between the actual critical rod configuration and the expected configuration during power operation not exceed 1%AK. CTS defines reactor power operation as any operation with the mode switch in the "STARTUP" or "RUN" position with the reactor critical and ! above 1% design power. The core reactivity anomaly surveillance must be performed under steady state power operations (no control rod movement or
^
core flow changes in progress) because of the small (< 1%) changes being evaluated. This is best performed after the generator is synchronized to the grid which requires the mode switch to be in RUN. In the STARTUP MODE, thermal power is low enough (s 5% RTP) such that reactivity anomalies are unlikely to occur. Therefore, proposed LCO 3.3.E is revised to be applicable only in the RUN MODE. Since proposed LCO 3.3.E will no longer be applicable in the STARTUP MODE, this change is less restrictive. 3/4.3 DOC 18
I 1 Attachment D No Significant Hazards Discussion l l l l
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL .The Code of Federal Regulations (10 CFR 50.91) requires licensees requesting an amendment to provide an analysis, using the standards in 10 CFR 50.92, that determines whether a significant hazards consideration exists. The following analysis is provided in accordarv6 with 10 CFR 50.91 and 10 CFR 50.92 for the proposed amendment. ADMINISTRATIVE CHANGES (Ai , A2, A3 ,4A , As, Ae, A7 , A.8, Ag, iA o,iiA , A 12,Ai3
, Ai4,and A s:i Labeled Discussion of Changes, CTS 3/4.3)
These proposed changes involve reformatting, renumbering, human factors, and rewording of the Technical Specifications and Bases. These changes, since they do not involve technical changes to the Technical Specifications, are administrative. All of the administrative changes conta,ned in the Discussion of Changes for this LCO are addressed by this evaluation. BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: The proposed changes involve reformatting, renumbering, and rewording of the existing Technical Specifications and Bases along with other changes to the Technical Specifications discussed above. The reformatting, renumbering, and rewording along with the other changes listed involves no technical changes to existing Technical Specifications. These changes do not involve any physical alteration of the plant (no new or different type of equipment will be installed), introduce any new tests, nor change methods governing normal plant operation.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: These proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed nor is any equipment being removed) nor change methods governing normal plant operation. The proposed change will not impose any new or different requirements nor eliminate any existing requirements. l I 3/4.3 - N.S.H.C. 1 1
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL ADMINISTRATIVE CHANGES (continued)
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: , i These change are administrative in nature and will not involve any technical changes. These changes do not involve any physical alteration of the plant (no new or different type of equipment will be installed nor is any equipment being removed), introduce any i new tests, nor change methods governing normal plant operation. 1 i 3/4.3 - N.S.H.C. 2
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 l REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (M i , M 2, M 3, M 4, Ms, Me, M 7, Ma, Mg, Mi o, Mii , and M12; Labeled Discussion of Changes, STS 3/4.3) These changes incorporate more restrictive changes into the current Technical Specifications by either making current requirements more stringent or by adding new requirements which currently do not exist. All of the more restrictive changes contained in the Discussion of Changes for this LCO are addressed by this evaluation. BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: The proposed changes provide more stringent requirements than those currently in the Technical Specifications. The more restrictive requirements will not alter the operation of process variables, structures, systems, or components as described in the safety analyses; therefore, they will not involve a significant increase in the probability of an accident occurring. The proposed changes will ensure compliance with, "NEDO-21231, Banked Position Withdrawal Sequence (BPWS)" which limits maximum rod worth such that fuel enthalpy addition due to a control rod drop accident (CRDA) will not exceed 280 cal /gm fuel enthalpy or require the plant be placed in a condition where the LCOs do not apply sooner. - In addition, changes are proposed to require entering a MODE in which the LCOs do not apply sooner than currently required. Therefore, the new requirements may decrease the consequences of an analyzed event.
- 2. Does the change create the possibility of a new or different kind of accident from any ]
accident previously evaluated? ! Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated l because of the following: These more restrictive and new requirements will not alter the plant configuration (no new or different type of equipment will be installed nor is any equipment being removed) or change methods goveming normal plant operation. The changes do impose different requirements; however, they are consistent with assumptions made in the safety analyses. 2/4.3 - N.S.H.C. 3
I-NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - MORE RESTRICTIVE (continued)
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: I l I Adding these new requirements and making existing ones more restrictive does not involve a physical alteration of the plant (no new or different type of equipment will be installed nor is any equipment being removed), introduce any new tests, or change methods governing normal plant operation. The proposed changes will ensure I compliance with BPWS which limits maximum rod worth such that fuel enthalpy addition due to a CRDA will not exceed 280 cal /gm fuel enthalpy or require the plant be placed in a condition where the LCOs do not apply sooner or require entering a MODE in which the LCOs do not apply sooner than currently required. j i 3/4.3 - N.S.H.C. 4
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - RELOCATIONS (Ri Labeled Discussion of Changes, CTS 3/4.3) This proposed change will relocate details of the methods for timing control rod drives (CRDs) to the BASES. BECo has evaluated this proposed Technical Specification change and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: This proposed change relocates details of the methods for timing control rod drives from the Technical Specifications to the BASES. The requirement to verify scram times is incorporated into proposed SR 3.3.B.1.4; therefore, it does not eliminate any requirements, or impose a new or different treatment of the requirements. The BASES are subject to the Technical Specifications (TS) Bases Control Program contained in the Administrative Controls Section of the Technical Specifications. Since any changes to the BASES will be in accordance with these requirements, no increase (significant or insignificant) in the probability or consequences of an accident previously evaluated will be allowed.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: This change relocates details of the methods for timing control rod drives to the BASES. This change will not alter the plant configuration (no new or different type of equipment will be installed nor is any equipment being removed) or change methods governing normal plant operation. This change will not impose different requirements and adequate control of information will be maintained. This change will not alter assumptions made in the safety analysis and licensing basis. 3/4.3 - N.S.H.C. 5
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - RELOCATIONS (continued) (R$Labeled Discussion of Changes, CTS 3/4.3)
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: This change relocates details of the methods for timing control rod drives not the requirement to ensure scram times are met. The requirement to verify scram times is incorporated into proposed SR 3.3.B.1.4, therefore, it does not eliminate any requirements, or impose a new or different treatment of the requirements. The requirements to be transposed from the Technical Specifications to the BASES are the same as the existing Technical Specifications. The BASES are subject to the Technical Specifications (TS) Bases Control Program contained in the Administrative Controls Section of the Technical Specifications. Since any changes to the BASES will be in accordance with these requirements, no increase (significant or insignificant) in the probability or consequences of an accident previously evaluated will be allowed. 3/4.3 - N.S.H.C. 6 I
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE L,, Labeled Discussion of Changes for CTS 3/4.3 CTS 3.3.A.2.a requires control rods that cannot be moved with control rod drive or scram pressure be considered inoperable, and that the reactor be brought to a shutdown condition within 48 hours unless investigation demonstrates that the cause of the failure is not due to a failed control rod drive mechanism collet housing. This proposed change will allow continued operation with one withdrawn control rod that cannot be moved with control rod drive or scram pressure (stuck rod) regardless of the reason for it being stuck (proposed LCO 3.3.B.1, ACTIONS A).. Therefore, this change is considered less restrictive. Continued operation with one stuck control rod is contingent upon (1) verification that the separation criteria is met (required ACTION A.1), (2) the stuck rod is disarmed (required ACTION A.2), (3) all OPERABLE control rods are exercised to ensure there are no other stuck rods (required ACTION A.3), and (4) Reactivity Margin requirements are satisfied (required ACTION A.4). When operating at s 20 % RTP, an additional requirement (A.5) to verify compliance with BPWS sequence or perform an analysis within 8 hours to ensure that the current positions do not create maximum incremental rod worth that would cause the CRDA limit of 280 cal /gm to be exceeded is imposed. NEDO-21231, " Banked Position Withdrawal Sequence", Section 7.2, January 1977 does not permit operation within the BPWS range while a stuck control rod exists unless analysis exists to support such operation. The existing limitation of CTS 3.3.A.2.a for investigating the reason for the failure to insert (e.g., failed collet housing) is being omitted. The requirement to determine the stuck condition was not due to collet housing failure was added to the PNPS TS in Amendment 14, February 3, 1976 because of circumferential cracks resulting from stress assisted intergranular corrosion occurring in the collet housings of drives at several plants. The purpose of Amendment 14 was to ensure that the reactor would not be operated with a large number of control rods with failed collet housings. The proposed ACTIONS will only allow continued operation with one stuck control rod provided all withdrawn control rods are tested within 24 hours to confirm no additional stuck control rods exist. The failure of a single control rod to insert (scram) will not prevent the reactor from reaching a subcritical condition. A completion time of 72 hours is allowed for ensuring reactivity margin requirements are inet. CTS does not specify a completion time which could be interpreted to be within 24 hours ; consistent with CTS 3.3.F. The 72-hour completion time is considered appropriate because of j the ACTIONS necessary to perform the analysis and, even with one control rod stuck in a ! withdrawn position, the remaining OPERABLE control rods will scram and provide the required shutdown reactivity. A completion time of 8 hours is allowed for ensuring compliance with BPWS sequence or perform a rod worth analysis when s 20 % RTP. The 8-hour completion time is considered appropriate because of the limited number of allowed out-of-sequence control rods, the low probability of a CRDA occurring during the time the control rods are out-of-sequence, and is consistent with other corrective actions required by NEDO-21231. A note is added to ACTION "A" that allows for bypassing the RWM in order to fulfill the required ACTIONS A.3 and A.5, provided the proper ACTIONS of proposed LCO 3.3.F (Rod Worth Minimizer) are taken. This is a human factors consideration to ensure clarity of the requirement and allowance. j 3/4.3 - N.S.H.C. 7 j
...l
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE Li , Labeled Discussion of Changes for CTS 3/4.3 (continued) BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? I Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following:
The probability of an accident previously evaluated is not increased because the proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The consequences of an accident previously evaluated are not increased because the failure of a single control rod to insert will not prevent the reactor from reaching a subcritical condition as long as shutdown margin requirements are met. Elimination of the requirement to shutdown if one rod is stuck due to potential collet finger failure is being made concurrently with another change that will require a reactor shutdown if more than one rod is stuck for any reason. This additional restriction ensures that the reactor will be shut down as soon as it is determined that more than one rod may fail to scram. This differs from the existing requirement that allows operation with multiple stuck rods that are not fully inserted, provided reactivity margin is met.
- 2. Does the change create the possibility of a new or different kind of accident from any ,
accident previously evaluated? Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The change does impose different requirements; however, the change is consistent with Shutdown Margin and CRDA assumptions made in the safety analysis. 3/4.3 - N.S.H.C. 8
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL I i TECHNICAL CHANGES - LESS RESTRICTIVE LtLabeled Discussion of Changes for CTS 3/4.3 (continued)
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant ! reduction in a margin of safety because of the following: l Elimination of the requirement to shutdown if one rod is stuck due to potential collet , finger failure will not decrease a margin of safety because this change is being made I concurrently with another change that will require a reactor shutdown if more than one rod is stuck for any reason. This additional restriction ensures that the reactor will be shut down as soon as it is determined that more than one rod may fail to scram and the assumptions used in the analysis of those accidents and transient that depend on a scram may no longer be met. The failure of a single control rod to insert will not prevent the reactor from reaching a suberitical condition as long as shutdown margin requirements are met. i l l I l 1 l 1 3/4.3 - N.S.H.C. 9
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) L2. Labeled Discussion of Changes for CTS 3/4.3 CTS 4.3.A.2 requires that all partially or fully withdrawn control rods be exercised at least once per week. This Surveillance Requirement (SR) could be satisfied by control rod withdrawal. However, it is possible for a control rod binding mechanism to exist that only prevents control rod insertion. In such a case, a withdrawal test will not detect the problem. Therefore, proposed SRs 4.3.B.1.1 and 4.3.B.1.2 require control rods to be inserted in lieu of the CTS requirement for " exercising". Since the purpose of the test is to ensure scram insertion capability, restricting the test to only allow control rod insertion increases the sensitivity of this test for detecting a problem that impacts this capability. The proposed requirements SR 4.3.B.1.1 and SR 4.3.B.1.2 will differentiate between fully and partially withdrawn rods. Fully withdrawn rods will still be inserted one notch once per 7 days. However, partially withdrawn rods will be inserted one notch once per 31 days. The rational for decreasing the frequency of exercising partially withdrawn rods from 7 to 31 days is that partially withdrawn control rods have a significantly greater affect on core flux distribution than do fully withdrawn control rods. Power reductions may be required each week to perform this test on the partially withdrawn control rods. This potential impact on plant capacity is deemed excessive given the following considerations:
- 1) At full power a large percentage of control rods (typically 80-90%) are fully withdrawn and would continue to be exercised each week. This represents a significant sample size when looking for an unexpected random event.
- 2) Operating experience has shown " stuck" control rods to be a rare event while operating.
1
- 3) Partially withdrawn control rods are exercised during operations to maintain power level. Should a stuck rod be discovered, all of the remaining control rods (including those partially withdrawn) must be exercised within 24 hours (proposed LCO 3.3.B.1, ACTION A.3).
BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: i The probability of an accident previously evaluated is not increased because the proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. 3/4.3 - N.S.H.C. 10 _j
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (L2Labeled Comment / Discussion for CTS 3/4.3) (continued) The consequences of an accident previously evaluated are not significantly increased because the proposed change only increases the interval between performance of a surveillance for only 10% to 20% of the control rods (those that are partially withdrawn). The purpose of the surveillance is to verify that rods can be inserted, thus verifying that rods are not stuck and scram capability is maintained. The 80% to 90% of the control roda that are fully withdrawn will continue to be tested at the 7 day frequency and should a stuck control rod be found, all withdrawn control rods will have to be tested within 24 hours. In addition, this change is being implemented concurrently with more restrictive requirements goveming continued operation with stuck and inoperable control rods. Collectively, these changes provide assurance that when a scram is required, the assumptions used in the accident analysis (i.e., most reactive rod fully withdrawn does not scram) will be met.
- 2. Does the change create the possibility of a new or different kind of accident from any I accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the I possibility of a new or different kind of accident from any accident previously evaluated ! because of the following: The proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, i modified, tested, or inspected. The proposed change increases the interval between 1 performance of surveillances designed to verify that rods can be inserted for only 10% to 20% of the control rods (those that are partially withdrawn) not the manner in which the curveillance is performed.
- 3. Does this change involve a significant reduction in a margin cf safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: A margin of safety is not reduced even though the proposed increase in the interval between performances of a surveillance may increase the time before a stuck rod is discovered. However, the increased frequency does not apply to fully withdrawn rods I which represent a significant sample size (80% to 90%) when looking for an infrequent, random event. Additionally, this change is being implemented concurrently with more restrictive requirements goveming continued operation with stuck and inoperable control ! rods. Collectively, these changes provide assurance that when a scram is required, the assumptions used in the accident analysis (i.e., most reactive rod fully withdrawn does not scram) will be met. 3/4.3 - N.S.H.C. 11
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) (L3Labeled Comment / Discussion for CTS 3/4.3) CTS 4.3.A.2 requires all OPERABLE control rods be exercised once every 24 hours if reactor operation continues with three or more inoperable control rods. The original intent of this requirement was to assure the reliability of the remgining OPERABLE control rods if pov er operations were to continue with three or more non fully inserted, inoperable control roc's. If the inoperable control rods were fully incerted and disarmed, they would not be considered inoperable (CTS 3.3.A.2.c) and the increased SURVF.lLLANCE FREQUENCY would not apply. The proposed requirement for contret rods that are inoperable but not stuck (LCO 3.3.B.1, ACTION C), is to fully insert and disarm the inoperable rod (s). Since continued power operation with non-fully inserted, inoperable control rods will not be allowed, there will be no requirement to exercise the OPERABLE rods to verify their operability other than the scheduled surveillance requirements in proposed SR 4.3.B.1.1 and SR 4.3.B.1.2. CTS 4.3.A.2 also requires all OPERABLE control rods be exercised once every 24 hours if reactor operation continues with a stuck control rod for which CRD mechanism failure has not been ruled out. For a stuck control rod, regardless of the reason, the proposed requirement will require all OPERABLE rods to be inserted at least one notch within 24 hours. This will verify the stuck control rod is not caused by a generic failure that would interfere with scram capability. Thereafter, continued testing of control rods will be at the normal frequency. Operating experience has shown stuck control rods to be a rare event during power operations. 1 BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: The proposed change does not increase the probability of an accident previously J evaluated because the change will not involve any physical changes to plant systems, 9tructures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The proposed change will not increase the consequences of an accident previously evaluated because continued power operation will not be allowed with inoperable (not stuck) control rods not fully inserted and verification that all OPERABLE control rods can be inserted will be required within 24 hours after discovery of a stuck control rod. In addition, if more than one control rod is stuck the reactor must be brought to HOT SHUTDOWN within 12 hours (LCO 3.3.B.1, ACTION B.1). 3/4.3 - N.S.H.C. 12
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D I SECTION 3/4.3 i REACTIVITY CONTROL l TECHNICAL CHANGES - LESS RESTRICTIVE (L3Labeled Discussion of Changes for CTS 3/4.3) (continued)
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibilRy of a new or different kind of accident from any accident previously evaluated i because of the following:
)
l The proposed chango will not involve any physical changes to plant systems, structures, , or components (SSCs), or the manner in which these SSCs are operated, maintained, l modified, tested, or inspected. Continued operation will only be allowed with one stuck control rod and all other inoperable control rods must be fully inserted and disarmed.
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant i reduction in a margin of safety because of the following: The purpose of this surveillance was to assure the reliability of the remaining OPERABLE control rods to insert if power operations were to continue with three or more non-fully inserted, inoperable (not stuck) control rods or one stuck control rod. Since an inoperable control rod (not stuck) can be inserted, it is not subject to the i generic failure the surveillance was intended to identify, therefore, the surveillance is not appropriate for identifying common cause failures. For a stuck rod, the verification that all OPERABLE control rods can be inserted at least one notch within 24 hours will still apply. Operating experience on control reliability has shown that additional testing at an increased frequency is unnecessary. Additionally, the proposed change is being implemented concurrer.tly with more restrictive requirements governing continued operation with stuck and inoperable control rods. These more restrictive requirements ; include fully inserting all inoperable control rods within 3 hours and requiring reactor ! shutdown within 12 hours if more than one rod is stuck. Collectively, these changes l provide assurance that when a scram is required that, at a minimum, the assumptions i used in the accident analysis (i.e., most reactive control rod fully withdrawn) will be met. l l I 3/4.3 - N.S.H.C. 13 l 1
l NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) (L4Labeled Discussion of Changes for CTS 3/4.3) in addition to verifying that the drive does not go to overtravel, CTS 4.3.B.1 also requires observance of a discemible response of the nMear instrumentation when a control rod is withdrawn the first time following a refueling outage or maintenance. An indication of a flux level change on nuclear instruments demonstrates control rod motion, but does not demonstrate that a control rod is coupled, as is the intent of existing requirement 4.3.B.I.a. Therefore, this requirement is deleted. BECo has evaluated these proposed Technical Specification changes and has determined that l no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNP 3 in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: The proposed change eliminates the requirement to verify discernible neutron instrument response to control rod motion the first time a rod is withdrawn after refueling , or maintenance. The probability of an accident is not increased because the proposed l change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The consequences of an accident are not increased because the CRDA analysis assumes a single failure of the control rod drive system when a single control rod drops out of the core from the fully inserted position after l being disconnected from its drive and after the drive has been retracted to the fully l withdrawn position while reactor power is less than 20%. During startup and before exceeding 20% reactor power, a large percentage of the rods are fully withdrawn in the normal course of a startup. All fully withdrawn rods are subjected to verification of coupling by the overtravel test. Since the deleted surveillance was intended to identify a rod that is both uncoupled and stuck in the fully inserted position, the number of fully withdrawn rods in the normal withdrawal sequence before reaching 20% power constitutes a very large sample being use6 to identify a random and very rare event. Therefore, there is no increase in the protsability that more than one control rod will remain uncoupled and stuck in the fully inserted position without being identified. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. 3/4.3 - N.S.H.C. 14
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (L4Labeled Discussion of Changes for CTS 3/4.3) (continued)
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: ' This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. Observation ofindication of a flux level change on nuclear instruments when a control rod is withdrawn does not ensure coupling. The requirement to verify the control rod does not go to overtravel when withdrawn to the full out position, the only positive test of coupling integrity, is being retained.
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: A response to control rod motion on nuclear instrumentation is indicative that a contrni rod is following its drive, but gives no indication as to whether a control rod is coupled. Likewise, failure to have a response to rod motion on nuclear instrumentation does not indicate that a rod in uncoupled. Although operators will continue to monitor nuclear instrumentation response during control rod motion, the results are insufficiently conclusive to use the results as a surveillance test for the verification of rod coupling. The CRDA analysis assumes a single failure of the control rod drive system when a single control rod drops out of the core from the fully inserted position after being disconnected from its drive and after the drive has been retracted to the fully withdrawn ) position while reactor power is less than 20%. During startup and before exceeding 20% reactor power, a large percentage of the rods are fully withdrawn in the normal course of a startup. All fully withdrawn rods are subjected to verification of coupling by the overtravel test. Since the deleted surveillance was intended to identify a rod that is both uncoupled and stuck in the fully inserted position, the number of fully withdrawn rods in the normal withdrawal sequence before reaching 20% power constitutes a very large sample being used to identify a random and very rare event. 3/4.3 - N.S.H.C. 15 l l
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3
' l' REACTIVITY CONTROL l TECHNICAL CHANGES - LESS RESTRICTIVE (continued) l (L5Labeled Discussion of Changes for CTS 3/4.3)
CTS 4.3.B.1 requires observation that the control rod does not go to the overtravei position after maintenance without specifying the type of maintenance. The proposed SR 4.3.B.1.3 will only require observing the control rod does not go to the overtravel position after maintenance that could affect coupling integrity. Since the purpose of the surveillance is to determine that the control rod is coupled, restricting the performance to maintenance that could affect coupling integrity is appropriate. BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in , I accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for ! the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: o The purpose of this surveillance is to ensure that coupling integrity is maintained, if the maintenance that was performed does not have the potentid to affect coupling then there is no reason to suspect that the rod has become uncoupbd
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected.
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: As discussed above, if the maintenance that was performed does not have the potential to affect coupling then there is no reason to suspect coupling integrity has been lost. Also, SR 3.3.B.1.3 will also require that coupling integrity be verified the next time the control rod is withdrawn to the full out position which is usually immediately after retuming the rod to service. 3/4.3 - N.S.H.C. 16
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) (Le Labeled Discussion of Changes for CTS 3/4.3) CTS 3.3.B.3.a does not allow control rods to be moved when the reactor is below 20% rated 1 power, except to shutdown the reactor, unless the Rod Worth Minimizer (RWM) is OPERABLE. ! A maximum of two rods may be moved below 20% design power when the RWM is inoperable if all other rods, except those which cannot be moved with control rod drive pressure, are fully inserted. Proposed LCO 3.3.F, " Rod Worth Minimizer" will continue to require operability of the RWM below 20% of design power; however, the requirements on control rod movement are being relaxed. Proposed LCO 3.3.F ACTION A will still require suspension of control rod movement when the RWM is inoperable during Startup unless withdrawal has not been performed with the RWM inoperable in the last 12 months and a second licensed operator or other qualified member of the technical staff verifies movement of control rods is in compliance with the banked position withdrawal sequence (BPWS). The RWM function assists and supplements the operator with an effective backup control rod monitoring routine that enfo:ces adherence to established startup, shutdown, and low power level control rod procedures. Allowing a second licensed operator or other qualified member of the technical staff ?.o verify control rod movement is in compliance with BPWS also provides effective control. Not allowing more than one startup per 12 months will ensure that the RWM is maintained OPERABLE. Although CTS 3.3.B.3. allows control rod movement to shutdown the reactor without any constraints, proposed LCO 3.3.F, ACTION B will also require a second licensed operator or other qualified member of the technical staff to verify movement of control rods is in compliance with BPWS. BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: The proposed change will allow either a second licensed operator or other qualified ! members of the technical staff to verify movement of control rods when the RWM is ! inoperable. The function of the RWM is to control adherence to the control rod I withdrawal and insertion sequence. The use of a second licensed operator or other qualified members of the technical staff to perform these control rod movement verifications also provides effective control. Not allowing more than one startup per 12 months with the RWM inoperable will ensure that the RWM ic maintained OPERABLE. 3/4.3 - N.S.H.C. 17
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D L SECTION 3/4.3 REACTIVITY CONTROL l TECHNICAL CHANGES - LESS RESTRICTIVE (Le Labeled Discussion of Changes for CTS 3/4.3) (continued)
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the , possibility of a new or different kind of accident from any accident previously evaluated because of the following: This proposed change will not involve any physical changes to plant systems, I structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. Compliance with the requirement to follow the BPWS are still maintained.
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: The proposed change will limit control rod movement verification when the RWM is inoperable, to once per 12 months. Only licensed operators or other qualified members of the technical staff (i.e., personnel trained in accordance with an approved training l program) will be allowed to verify control rod movement. Each of these individuals, as a l part of their qualification process, receive training in the use of the RWM, the Control Rod Drive System, and permissible control rod sequences. 1 O i l 3/4.3 - N.S.H.C. 18
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) (L7Labeled Discussion of Changes for CTS 3/4.3) CTS 4.3.B.3.a requires verifying the correctness of the control rod withdrawal sequence input to the RWM computer prior to control rod withdrawal for startup and prior to insertion to reduce power below 20%. This requires verification for each plant startup and shutdown. Proposed SR 4.3.F.3 will require this verification only once following loading of the sequence into the RWM computer. The potential for error occurs when the sequence is initially loaded into the computer. Once the rod withdrawal sequence is verified, controls are in place to ensure that changes cannot be made without prior approval. Any change would require reverification. BECo has evaluated these proposed Technical Specification changes and has determined that , no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?.
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following. The RWM does not monitor core thermal conditions, but simply enforces preprogrammed rod patterns as a backup intended to prevent reactor operator error in selecting or positioning contrd rods. Once the sequence is loaded into the RWM computer and verified, there is no reason to believe that it will change inadvertently. Controls are in place to ensure that required changes are performed and verified by technically qualified individuals.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated , because of the following: , This proposed change will not involve any physical changes to plant systems, stre:tures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, cd inspected. 3/4.3 - N.S.H.C. 19
l NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (L7Labeled Discussion of Changes for CTS 3/4.3) (continued)
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: The RWM does not monitor core thermal conditions, but simply enforces preprogrammed rod patterns as a backup intended to prevent reactor operator error in selecting or positioning control rods. Once the sequence is loaded into the RWM i computer and verified there is no reason to believe that it will change inadvertently. ! Controls are in place to ensure that required changes are performed and verified by ! technically qualified individuals. i l l 3/4.3 - N.S.H.C. 20
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) (La Labeled Discussion of Changes for CTS 3/4.3) CTS 3.3.F states that " Specifications 3.3.A through D above do not apply when there is no fuel in the reactor vessel." This implies that Specifications A through D must be met during all MODES of operation when there is fuel in the reactor vessel. In the HOT SHUTDOWN and COLD SHUTDOWN MODES, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod OPERABILITY during these conditions. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling conditions. Therefore, proposed LCOs 3.3.B.1 is revised to require APPLICABILITY only in the RUN and STARTUP MODES, or REFUEL MODE when the reactor vessel head is fully tensioned. Since control rod scram times and control rod scram accumulators are conditions for control rod OPERABILITY, LCOs 3.3.C and 3.3.D are also revised accordingly. In addition, there are no design bases accidents (DBAs) or abnormal operational transients (AOTs) identified for conditions when one or less control rods are withdrawn that require a scram. Because the proposed changes do not require APPLICABILITY in all MODES, they are less restrictive. BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because of the following: Control rod OPERABILITY is required to ensure reactivity control and power level control and to mitigate the consequences of design basis accidents (DBAs) or abnormal operational transients (AOTs). The station safety analysis does not identify any DBAs or (AOTs) that require control rod scram under conditions where no more than one control rod is with drawn. In the HOT SHUTDOWN and COLD SHUTDOWN M00ES, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied, in the REFUEL MODE, only one control rod can be withdrawn. This provides adequate requirements for control rod OPERABILITY during these conditions. CTS 3/4.10 provides requirements to ensure that core reactivity is within the capability of the controi rods and to prevent criticality during refueling conditions. 3/4.3 - N.S.H.C. 21
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (La Labeled Discussion of Changes for CTS 3/4.3) (continued)
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because of the following: This proposed change will not involve any physical changes to plant systems, structures, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected.
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: The proposed change will continue to require control rod OPERABILITY, scram function, and accumulator OPERABILITY during plant conditions requiring reactivity control to mitigate the consequences of DBAs and AOTs. The changes do not impact the ability of equipment to maintain the plant within acceptable limits and continues to provide assurance that plant operation is maintained within safety analysis assumptions. 3/4.3 - N.S.H.C. 22
l l 1 NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (continued) (Le Labeled Discussion of Changes for CTS 3/4.3) CTS 3.3.E requires the reactivity equivalent of the difference between the actual critical rod configuration and the expected configuration during power operation. CTS defines REACTOR POWER OPERATION as any operation with the mode switch in the "STARTUP" or "RUN" position with the reactor critical and above 1% design power. The core reactivity anomaly , surveillance must be performed under steady state operations (no control rod movement or ] core flow changes in progress) because of the small (< 1%) changes being evaluated. This is l best performed after the generator is synchronized to the grid which requires the mode switch to be in RUN. Therefore, proposed LCO 3.3.E is revised to be applicable only in the RUN MODE. Since proposed LCO 3.3.E will no longer be applicable in the STARTUP MODE, this change is less restrictive. BECo has evaluated these proposed Technical Specification changes and has determined that no significant hazards consideration exists. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The following evaluation is provided for l the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an
! accident previously evaluated? Operation of PNPS in accordance with the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously 1 evaluated because of the following: ! The reactivity anomaly LCO provides a simple comparison of predicted versus actual conditions and is not an initial condition of a design oasis accident (DBA) or abnormal operational transient (AOT).
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Operation of PNPS in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated oecause of the following: Reactivity anomaly is not a structure, system, or component, therefore, this proposed change will not involve any physical changes to the plant or the manner in which the plant is operated. 3/4.3 - N.S.H.C. 23 a
NO SIGNIFICANT HAZARDS CONSIDERATIONS ATTACHMENT D SECTION 3/4.3 REACTIVITY CONTROL TECHNICAL CHANGES - LESS RESTRICTIVE (Le Labeled Discussion of Changes for CTS 3/4.3) (continued)
- 3. Does this change involve a significant reduction in a margin of safety?
Operation of PNPS in accordance with the proposed change will not involve a significant reduction in a margin of safety because of the following: The reactivity anomaly is not an inP.ial condition of a design basis accident (DBA) or abnormal operational transient (AOT). Also, in the STARTUP MODE, enough operating margin exists to limit the effects of a reactivity anomaly, and thermal power is low enough (s; 5% RTP) such that reactivity anomalies are unlikely to occur. l 1 l 3/4.3 - N.S.H.C. 24
i l l l l 1 l l l Attachment E I Proposed Final Technical Specification Pages and Bases 1
)
1 i
- TABLE OF CONTENTS 1.0. DEFINITIONS 1-1 2.0 SAFETY LIMITS 2-1 2.1 Safety Limits 2-1 2.2 Safety Limit Violation 2-1 BASES B2-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.1 REACTOR PROTECTION SYSTEM 4.1 3/4.1-1 BASES B3/4.1-1 3.2 PROTECTIVE INSTRUMENTATION 4.2 3/4.2-1 A. Primary Containment isolation Functions A 3/4.2-1 B. Core and Containment Cooling Systems B 3/4.2-1 C. Control Rod Block Actuation C 3/4.2-2 D. Radiation Monitoring Systems D 3/4.2-2 E. Drywell Leak Detection E 3/4.2-3 F. Surveillance Information Readouts F 3/4.2-3 '
G. Recirculation Pump Trip / Altemate Rod G Insertion 3/4.2-4 H. Drywell Temperature H 3/4.2-5 BASES B3/4.2-1 3.3 REACTIVITY CONTROL 4.3 3/4.3-1 A. Reactivity Margin - Core Loading A 3/4.3-1 B. Control Rod Operability B 3/4.3-2 C. Scram insertion Times C 3/4.3-7 D. Control Rod Accumulator D 3/4.3-8 E. Reactivity Anomalies E 3/4.3-10 F. Rod Worth Minimizer (RWM) F l 3/4.3-11 l G. Scram Discharge Volume G 3/4.3-12 J H. Rod Pattem Control H 3/4.3-13 BASES B3/4.3-1 i 3.4 STANDBY LIQUID CONTROL SYSTEM 4.4 3/4.4-1 BASES B3/4.4-1 3.5 CORE AND CONTAINMENT COOLING 4.5 3/4.5-1 SYSTEMS A. Core Spray and LPCI Systems A 3/4.5-1 B. Containment Cooling System B 3/4.5-3 C. HPCI System C 3/4.5-7 D. Reactor Core isolation Cooling (RCIC) System D 3/4.5-8 E. Automatic Depressurization System (ADS) E 3/4.5-9 4 F. Minimum Low Pressure Cooling and Diesel F Generator Availability 3/4.5-10
' G. (Deleted) G 3/4.5-11 'H. Maintenance of Filled Discharge Pipe H 3/4.5-12 BASES B3/4.5-1 PNPS i Amendment No. l
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL 4.3 REACTIVITY CONTROL A. Reactivity Marain - Core Loadina A. Reactivity Marain - Core Loadino LCO 3.3.A.1 SR 4.3.A.1 The core loading shall be limited to that Sufficient control rods shall be which can be made subcriticalin the withdrawn following a REFUELING most reactive condition during the OUTAGE when CORE ALTERATIONS l OPERATING CYCLE with the strongest were performed to demonstrate with a OPERABLE control rod in its full-out margin of 0.25 percent Ak that the core position and all other OPERABLE rods can be made subcritical at any time in I fully inserted. the subsequent fuel cycle with the strongest OPERABLE control rod fully APPLICABILITY: withdrawn and all other OPERABLE At all times when there is fuelin the reactor vessel. ACTIONS: A. LCO 3.3.A.1 cannot be met. 1 Be in HOT SHUTDOWN within 12 hours. l l l PNPS 3/4.3-1 Amendment No. l
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued)- 4.3 REACTIVITY CONTROL (continued) B. Control Rod Operability B. Control Rod Operability LCO 3.3.B.1 SR 4.3.B.1.1 NOTE-- Each control rod shall be OPERABLE. Not required to be performed until 7 days after the control rod is withdrawn ' APPLICABILITY: and thermal power is greater than the l LPSP of the RWM. RUN and STARTUP MODES; REFUEL . MODE when tne reactor vessel head is insert each fully withdrawn OPERABLE fully tensioned. (See also 3.10.D) control rod at least one notch once per ACTIONS A. One withdrawn control rod stuck. NOTE - - NOTE - Not required to be performed until Rod Worth Minimizer (RWM) may 31 days after the control rod is , be bypassed as allowed by LCO withdrawn and thermal power is greater { 3.3.F. than the LPSP of the RWM. 1 Verify stuck control rod is Insert each partially withdrawn j separated from other OPERABLE control rod at least one inoperable control rods by notch once per 31 days. two or more OPERABLE control rods immediately. SR 4.3.B.1.3 AND Verify each withdrawn control rod does not go to the withdrawn overtravel 2 Disarm the associated position. control rod drive (CRD) within 2 hours. a. Each time the control rod is withdrawn to " full out" position. 3 Perform SR 4.3.B.1.1 and AND SR 4.3.B.1.2 for each b. Prior to declaring control rod withdrawn OPERABLE OPERABLE after work on control control rod within 24 hours rod or CRD system that could from discovery of affect coupling. condition A concurrent with thermal power greater than SR 4.3.B.1.4 the Low Power Setpoint Verify each control rod scram time from (LPSP) of the RWM. fully withdrawn to notch position 04 is AND s 7 seconds in accordance with 4 Verify LCO 3.3.A.1 is met SR 4.3.C.1 or SR 4.3.C.2. within 72 hours. SR 4.3.B.1.5 AND Determine the position of each control (continued) rod once per 24 hours. PNPS 3/4.3-2 Amendment No.
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) B. Control Rod Operability (continued) B. Control Rod Operability (continued) LCO 3.3.B.1 (continued) 5 - NOTE Not applicable when thermal power > 20% RTP. Ensure stuck rod is in compliance with banked position withdrawal sequence (BPWS) sequence within 8 hours. M Verify control rod drop accident limit of 280 cal /gm is not exceeded within 8 hours. B. Two or more withdrawn control rods stuck. 1 Be in HOT SHUTDOWN within 12 hours. C, - NOTE-Separate condition entry is allowed for each control rod. One or more control rods inoperable for reasons other than condition A or B. 1 --NOTE - RWM may be bypassed as allowed by LCO 3.3.F. l i Fully insert inoperable control rod within 3 hours. AND 2 Disarm the associated j CRD within 4 hours. ' (continued) l PNPS 3/4.3-3 Amendment No. l ! f
LIMITING CONDITIONS FOR OPERATL.4 SURVEILLANCE REQUIREMENTS l 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued)
- 8. Control Rod Operabi;ity (continued) B. Control Rod Operability (continued)
LCO 3.3.B.1 (continued) D. NOTE Not applicable when thermal power > 20% RTP. Two or more inoperable control rods not in compliance with BPWS and not separated by two or more OPERABLE control rods. 1 Restore compliance with BPWS within 8 hours. M 2 Verify control rod drop accident limit of 280 cal /gm is not exceeded within 8 hours.
!3 Restore control rod (s) to OPERABLE status within 8 hours.
E. - NOTE -- Not applicable when thermal power > 20% RTP. One or more groups with four or more inoperable control rods. 1 Restore control rod (s) to OPERABLE status within 8 hours. F. Required action and associated completion time of condition A, C, D, or E not met. M Nine or more control rods inoperable. 1 Be in HOT SHUTDOWN within 12 hours. PNPS 3/4.3-4 Amendment No.
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) B. Control Rod Operability (continued) B. Control Rod Operability (continued) LCO 3.3.B.2 SR 4.3.B.2 The control rod drive housing support The control rod drive housing support system shall be in place. system shall be inspected after reassembly and the results of the APPLICABILITY: inspection recorded. During reactor power operation and when the reactor coolant system is pressurized above atmospheric pressure with fuel in the reactor vessel. ACTIONS: A. LCO 3.3.B.2 cannot be met. 1 Be in COLD SHUTDOWN within 24 hours. i l 4 PNPS 3/4.3-5 Amendment No. l
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) B. Control Rod Operability (continued) 8. Control Rod Operability (continued) LCO 3.3.B.3 SR 4.3.B.3 Control rods shall not be withdrawn for Prior to control rod withdrawal for startup unless at least two source range startup, verify that at least two source channels have an observed count rate range channels have an observed equal to or greater than three counts count rate of at least three counts per per second. second. APPLICABILITY: , I Prior to withdrawing control rods for i startup. I ACTIONS: A. LCO 3.3.B.3 cannot be met. 1 Place the mode switch in shutdown immediately. PNPS 3/4.3-6 Amendment No.
LIMITING CONDITIONS FOR OPERATION SURVElLLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) C. Scram insertion Times C. Scram insertion Times LCO 3.3.C SR 4.3.C.1 1 Average scram insertion time for all Following each REFUELING OUTAGE, l OPERABLE control rods from de- or after a reactor shutdown that is energization of the scram pilot valve greater than 120 days, each solenoids to dropout (DO) of OPERABLE control rod shall be I notches 04,24,34, and 44 shall be subjected to scram time tests from the no greater than: fully withdrawn position. If testing is not accomplished with the nuclear system Notch Average Scram pressure above 950 psig, the measured Pesition Times (seconds) scram insertion time shall be 44 DO 0.508 extrapolated to reactor pressures above 34 DO 1.252 950 psig using previously determined 24 DO 2.016 correlations. Testing of all OPERABLE 04 DO 3.578 control rods shall be completed prior to exceeding 40% rated thermal power. 2 Average scram insertion time for the three fastest OPERABLE control SR 4.3.C.2 rods in each group of four control Within each 120 days of operation, a rods in all two by two arrays from de-energization of the scram pilot minimum of 10% of the control rod valve solenoids to dropout (DO) of drives, on a rotating basis, shall be notches 04,24,34, and 44 shall be scram tested as in SR 4.3.C.1. An I n greater man. evaluation shall be completed every 120 days of operation to provide Notch Average Scram reasonable assurance that proper Pesition Times (seconds) pedormance is be,ng i maintained. 44 DO 0.538 34 DO 1.327 24 DO 2.137 04 DO 3.793 APPLICABILITY: RUN and STARTUP MODES; REFUEL MODE when the reactor vessel head is fully tensioned. ACTIONS: A. LCO 3.3.C cannot be met. 1 Be in HOT SHUTDOWN within 12 hours. PNPS 3/4.3-7 Amendment No. l
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) D. Control Rod Accumulators D. Control Rod Accumulators LCO 3.3.D SR 4.3.D Each control rod scram accumulator shall be OPERABLE. Once a shift, check the status of the ressure and leve.' alarms for each APPLICABILITY: accumulator. RUN and STARTUP MODES; REFUEL MODE when the reactor vessel head is fully tensioned. ACTIONS: NOTE , Separate condition entry is allowed for each control rod scram accumulator. A. Control rod scram accumulator (s) inoperable with reactor steam j dome pressure 2 950 psig. l 1.1 Verify no adjacent OPERABLE control rod has an inoperable scram ; accumulator within 1 1 hour. AND 1.2 Verify no adjacent control rod is electrically disarmed in a non-fully inserted position within 1 hour. 2 Declare the associated control rod inoperable within 1 hour. B. Control rod scram accumulator (s) inoperable with reactor steam dome pressure < 950 psig or reactor thermal power s; 20 % RTP. 1 Restore inoperable accumulator to OPERABLE status within 8 hours. 2 Declare the associated control rod inoperable 1 within 8 hours. (continued) PNPS 3/4.3-8 Amendment No. i 1
LIMITING CONDITIONS FOR OPERATION {iURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) D. Control Rod Accumulatoa (continued) D. Control Rod Accumulators (continued) LCO 3.3.D (continued) C. Two or more control rod accumulators inoperable, concurrent with loss of charging water pressure, when reactor j steam dome pressure 2 950 psig. 1 Restore charging water header pressure within 20 minutes. AND 2 Restore inoperable accumulator (s) to OPERABLE status within 8 hours. D. Two or more control rod accumulators inoperable, concurrent with loss of charging water pressure, when reactor steam dome pressure < 950 psig. 1 Verify all control rods associated with inoperable accumulators are fully inserted immediately. AND 1 1 2 Declare the associated control rods inoperable within i hour. E. Required action and associated completion time if C.1 or D.1 not j met. 1 - NOTE l Not applicable if all l inoperable control rod I scram accumulators are associated with fully inserted control rods. Place the reactor mode - switch in the shutdown position immediately. PNPS 3/4.3-9 Amendment No. l 1
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) E. Reactivity Anomalies E. Reactivity Anomalies LCO 3.3.E SR 4.3.E The reactivity equivalent of the During startups following REFUELING difference between the actual critical OUTAGES, the critical rod rod configuration and the expected configurations will be compared to the configuration shall not exceed 1% AK. expected configurations at selected operating conditions. These APPLICABILITY: comparisons will be used as base data RUN MODE
'** Y * "" ""9 """9 subsequent power operation throughout ACTIONS: the fuel cycle. At speciiic power operating conditions, the critical rod A. Limit exceeded. configuration will be compared to the configuration expected based upon 1 Be in HOT SHUTDOWN appropriately corrected past data. This within 12 hours. comparison will be made at least every full power month.
PNPS 3/4.3-10 Amendment No.
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) F. Rod Worth Minimizer (RWM) F. Rod Worth Minimizer (RWM) LCO 3.3.F SR 4.3.F.1 The RWM shall be OPERABLE. Perform an INSTRUMENT FUNCTIONAL TEST of the RWM prior APPLICABILITY: to control rod withdrawal for startup or RUN and STARTUP MODES with reactor thermal power s; 20 % RTP. SR 4.3.F.2 ACTIONS: Verify the RWM automatic bypass setpoint to be > 20% RTP every 24 A. RWM inoperable during reactor months. startup. l SR 4.3.F.3 l 1 Immediately suspend control rod movement Verify control rod sequences input to except by scram. the RWM are in conformance with O R- BPWS prior to declaring RWM OPERABLE following loading of 2.1 Immediately verify by sequence into RWM. administrative methods that startup with RWM inoperable has not been performed in the last 12 months. AND 2.2 Verify movement of control l rods is in compliance with BPWS by a second licensed operator or other qualified member of the technical staff during control rod movement. B. RWM inoperable during reactor shutdown. 1 Verify movement of control rods is in accordance with BPWS by a second licensed operator or other qualified member of the technical staff during control rod movement. PNPS 3'4.3-11 Amendment No. l
I LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS , 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) G. Scram Discharae Volume G. Scram Discharae Volume LCO 3.3.G SR 4.3.G 1 The scram discharge volume drain & Verify scram discharge volume drain vent valves shall be OPERABLE. and vent valves open at least once per month. APPLICABILITY: SR 4.3.G.2 i RUN and STARTUP MODES; l REFUEL MODE when the reactor Test scram discharge volume drain and j vessel head is fully tensioned. vent valves as specified in 4.13. These valves may be closed intermittently for ACTIONS: testing under administrative control. A. Any scram discharge volume drain SR 4.3.G.3 or vent valves made or found inoperable. During each REFUELING INTERVAL verify the scram discharge volume drain 1 Be in HOT SHUTDOWN and vent valves. within 12 hours. a Close within 30 seconds after receipt of a reactor scram signal. l AND b Open when the scram is reset. I l l l I
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I i I l l l l l PNPS 3/4.3-12 Amendment No, l l 2
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) H. Rod Pattern Control H. Rod Pattern Control LCO 3.3.H SR 4.3.H All OPERABLE control rods shall Verify all OPERABLE control rods comply with the requirements of the comply with BPWS every 24 hours. BPWS. APPLICABILITY: RUN and STARTUP MODES with reactor thermal power s 20 % RTP. , 1 ACTIONS I A. One or more OPERABLE control j rods not in compliance with BPWS. l I NOTE RWM may be bypassed as allowed by LCO 3.3.F. { l Move associated control l rod (s) to correct position within 8 hours. M 2 Verify control rod drop accident limit of 280 caligm is not exceeded within 8 hours. M 3 Declare associated control rod (s) inoperable within 8 hours. (continued) PNPS 3/4.3-13 Amendment No. l
r LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS ( 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued) i l H. Rod Pattern Control (continued) H. Rod Pattern Control (continued) l LCO 3.3.H (continued) , I l B. Nine or more OPERABLE control rods not in compliance with BPWS. , 1 NOTE RWM may be bypassed as , allowed by LCO 3.3.F. Immediately suspend withdrawal of control rods. AND 2 Place the reactor mode switch in the shutdown position within 1 hour. l PNPS 3/4.3-14 Amendment No.
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