ML022700500

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Proposed Amendment 181a Application for Technical Specification Change Regarding Allowed Outage Time for the Individual Rod Position Indicator System
ML022700500
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 09/18/2002
From: Coutu T
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-02-086
Download: ML022700500 (15)
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Text

Kewaunee Nuclear Power Plant Point Beach Nuclear Plant N490 Highway 42 6610 Nuclear Road Kewaunee, Wl 54216-9511 Two Rivers, Wl 54241 9203882560 920 755 2321 NMC Committed to NuclearExcellenc" Kewaunee / Point Beach Nuclear Operated by Nuclear Management Company, LLC NRC-02-086 10 CFR 50.90 September 18, 2002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Ladies/Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Proposed Amendment 181 a Application For Technical Specification Change Regarding Allowed Outage Time For The Individual Rod Position Indicator System.

Reference 1) Letter from Mark E. Warner (NMC) to Document Control Desk (NRC), dated January 14, 2002, "Proposed Amendment 181 to the Kewaunee Nuclear Power Plant Technical Specifications."

2) Letter from John G. Lamb (NRC) to Mark E. Warner (NMC), dated May 3, 2002, "Request For Additional Information Related To Request For Proposed Amendment To Revise Kewaunee Nuclear Power Plant Technical Specification Section 3.10.f (TAC NO MB3825)."
3) Letter from Mark E. Warner (NMC) to Document Control Desk (NRC), dated July 12, 2002, "Response to Nuclear Regulatory Commission Request For Additional Information Regarding Kewaunee Nuclear Power Plant Proposed Amendment 181."

In accordance with the provisions of 10 CFR 50.90, Nuclear Management Company, LLC, (NMC) submitted, in reference 1, a request for an amendment to the Technical Specifications (TS) for the Kewaunee Nuclear Power Plant.

The proposed amendment was submitted using MicroSoft Word and reformats TS 3.10.f to more closely resemble the format of Improved Standard Technical Specification (ISTS).

The proposed amendment provides an allowed outage time (AOT) for the Individual Rod Position Indicator (IRPI) system of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with more than one IRPI per group inoperable. The TS did not previously have an explicit AOT for this condition.

Docket 50-305 NRC-02-086 September 18, 2002 Page 2 In reference 2, the NRC requested additional information associated with NMC's submittal.

NMC's response to the RAI is documented as referenced 3. NMC has committed to the following two technical specification changes as noted in reference 3. They are:

1. Technical Specification 3.1O.f.C.1, changes Completion Time from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
2. Technical Specification 3.10.f.D, adds requirement for Bank Demand Step Counter System operability consistent with Standard Technical Specifications.

Both the Completion Time change and the Bank Demand Step Counter System addition are consistent with NUREG-1431, Standard Technical Specifications for Westinghouse Plants, Revision 2. Additional comments were added to the TS under the notes section to inform the operators that this additional instrumentation is also available to verify Rod Position or Demand Counter position respectively. Although these instruments are not completely redundant, they provide information associated with the rod or demand counter position while clarifying acceptable indication of rod or bank demand position.

These changes have been made and are hereby submitted. The description of the proposed changes, TS Bases, and the TS pages contained in reference 1 are still applicable, except for those changes contained in the attachments to this letter. Attachment 1 provides the changed TS pages marked up to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the changed TS Bases pages marked up to show the proposed changes. Attachment 4 provides revised (clean) TS Bases pages.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 18, 2002.

YLWAO- 1 (LA4 Thomas Coutu Site Vice President Kewaunee Nuclear Power Plant TLM Attachments: 1-Proposed Technical Specification Changes.

2-Revised Technical Specification Pages.

3-Proposed Technical Specification Bases Changes.

4-Revised Technical Specification Bases Pages.

cc: US NRC Region III US NRC Senior Resident Inspector Electric Division, PSCW

ATTACHMENT 1 To Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated September 18, 2002 Proposed Amendment 181 a Strikeout TS Pages:

TS 3.10-9 TS 3.10-10

Rod Position Indication 3.10.f 3.10 CONTROL ROD AND DISTRIBUTION LIMITS 3.10.f Rod Position Indication LCO 3.10.f The Individual Rod Position Indicator (IRPI) System and Demand Position Indication System shall be OPERABLE.

APPLICABILITY: OPERATING & HOT STANDBY ACTIONS NOTE

1. Separate Condition entry is allowed for each inoperable rod position indicator -and each demand position indicator.
2. IRPI can be satisified by individual board indication, or plant process computer, or conditioning module voltage.
3. Demand position may be satisfied by demand step counters, or plant process computer, or bank overlap verses group position provided the banks are properly sequenced, or pulse-to

-analog converter. _....................................................................

CONDITION REQUIRED ACTION COMPLETION TIME A. One IRPI per group A.1 Verify the position of the rods with Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable for one or inoperable position indicators more groups. indirectly by using core instrumentation (excore detector, or thermocouples, or movable incore detectors).

OR A.2 Reduce thermal power to *50% 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> RATED POWER.

B. More than one IRPI per B.1 Place the control rods under Immediately group inoperable, manual control.

AND B.2 Monitor and Record RCS Tav. Once per 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND B.3 Verify the position of the rods with Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable position indicators indirectly by using core instrumentation (excore detector, or thermocouples, or movable incore detectors).

Proposed Amendment 181a TS 3.10-9 09/18/2002

Rod Position Indication 3.10.f CONDITION REQUIRED ACTION COMPLETION TIME AND B.4 Restore inoperable position 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> indicators to OPERABLE status such that a maximum of one IRPI per group is inoperable.

C. One or more rods with C.1 Verify the position of the rods 8-4_hours inoperable position with inoperable position indicators indioaterfI RPI(s)_have indirectly by using core been moved in excess instrumentation (excore detector, of 24 steps in one or thermocouples, or movable direction since the last incore detectors).

determination of the rod's position. OR C.2 Reduce thermal power to *50% 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> RATED POWER.

D. One or more demand D.1. Verify by administrative means all Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> position indicator(s) per IRPIs for the affected group(s) are bank inoperable for one OPERABLE.

or more banks.

AND D.1.2 Verify the most withdrawn rod and Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> the least withdrawn rod of the affected group(s) are: _<12 steps apart when RTP is > 85 percent.

and <_24 steps apart when RTP is g 85 percent.

OR D.2 Reduce THERMAL POWER TO 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

<_50% RTP.

DE. Required action and DE.1 Be in HOT SHUTDOWN 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated completion time not met.

Proposed Amendment 181a TS 3.10-10 09/18/2002

ATTACHMENT 2 To Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated September 18, 2002 Proposed Amendment 181 a Affected TS Pages:

TS 3.10-9 TS 3.10-10

Rod Position Indication 3.10.f 3.10 CONTROL ROD AND DISTRIBUTION LIMITS 3.10.f Rod Position Indication LCO 3.10.f The Individual Rod Position Indicator (IRPI) System and Demand Position Indication System shall be OPERABLE.

APPLICABILITY: OPERATING & HOT STANDBY ACTIONS NOTE

1. Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator.
2. IRPI can be satisified by individual board indication, or plant process computer, or conditioning module voltage.
3. Demand position may be satisfied by demand step counters, or plant process computer, or bank overlap verses group position provided the banks are properly sequenced, or pulse-to a n alo.g _c o nv e rte r . ...............................................................................................

CONDITION REQUIRED ACTION COMPLETION TIME A. One IRPI per group A.1 Verify the position of the rods with Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable for one or inoperable position indicators more groups. indirectly by using core instrumentation (excore detector, or thermocouples, or movable incore detectors).

OR A.2 Reduce thermal power to <50% 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> RATED POWER.

B. More than one IRPI per B.1 Place the control rods under Immediately group inoperable, manual control.

AND B.2 Monitor and Record RCS Tag Once per 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND B.3 Verify the position of the rods with Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable position indicators indirectly by using core instrumentation (excore detector, or thermocouples, or movable incore detectors).

TS 3.10-9

Rod Position Indication 3.10.f CONDITION REQUIRED ACTION COMPLETION TIME AND B.4 Restore inoperable position 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> indicators to OPERABLE status such that a maximum of one IRPI per group is inoperable.

C. One or more rods with C.1 Verify the position of the rods 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable IRPI(s) have with inoperable position indicators been moved in excess indirectly by using core of 24 steps in one instrumentation (excore detector, direction since the last or thermocouples, or movable determination of the incore detectors).

rod's position.

OR C.2 Reduce thermal power to <50% 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> RATED POWER.

D. One or more demand D.1.1 Verify by administrative means all Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> position indicator(s) per IRPIs for the affected group(s) are bank inoperable for one OPERABLE.

or more banks.

AND D.1.2 Verify the most withdrawn rod and Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> the least withdrawn rod of the affected group(s) are: < 12 steps apart when RTP is > 85 percent, and

  • 24 steps apart when RTP is

< 85 percent.

OR D.2 Reduce THERMAL POWER TO 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

< 50% RTP.

E. Required action and E.1 Be in HOT SHUTDOWN 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated completion time not met.

TS 3.10-10

ATTACHMENT 3 To Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated September 18, 2002 Proposed Amendment 181 a Strikeout TS Bases Pages:

TS B3.10-9 TS B3.10-10

B.1, B.2, B.3, and B.4 When more than one IRPI per group fail, additional actions are necessary to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are limited. Placing the Rod Control System in manual ensures unplanned rod motion will not occur. Together with the indirect rod position determination available via core instrumentation will minimize the potential for rod misalignment. The immediate completion time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this condition.

Monitoring and recording reactor coolant Tg ensures that significant changes in power distribution and SDM are avoided. The once per hour completion time is acceptable because only minor fluctuations in Reaoter-reactor .ee.ant-coolant Syste,,-svstem temperature are expected at steady state plant OPERATING conditions. The position of the rods may be determined indirectly by use of the core instrumentation., Verification of control rod position once per eight hours is adequate for allowing continued full power operation for a limited 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time provides sufficient time to troubleshoot and restore the IRPI system to operation while avoiding the plant challenges associated with the shutdown without full rod position indication. Based on OPERATING experience, normal power operation does not require excessive rod movement. If one or more rods has been significantly (> 24 steps) moved, the required action of C.1 and C.2 below is required.

C.1 and C.2 These required actions clarify that when one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the position was last determined, the required actions of A.1 and A.2, or B.1, as applicable, are still appropriate but must be initiated promptly under required action C.1 to begin verifying that these rods are still properly positioned, relative to their group positions. If, within eih#-fLour hours, the rod positions have not been determined, thermal power must be reduced to <50% RATED POWER within eight hours to avoid undesirable power distributions that could result from continued operation at > 50% RATED POWER, if one or more rods are misaligned by more than 24 steps. The allowed completion time of eight-four hours provides an acceptable period of time to verify the rod positions.

D.1.1 and D.1.2 With one demand position indicator per bank inoperable, the rod positions can be determined by the IRPI System. Since normal power operation does not require excessive movement of rods.

verification by administrative means that the individual rod position indicators are OPERABLE and the most withdrawn rod and the least withdrawn rod are: < 12 steps apart when RTP is > 85 percent, and < 24 steps apart when RTP is < 85 percent within the allowed Completion Time of once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is adequate.

D.2 Reduction of THERMAL POWER to _< 50% RATED POWER puts the core into a condition where rod position is not significantly affecting core peaking factor limits. The allowed Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provides an acceptable period of time to verify the rod positions per Required Actions D.1.1 and D.1.2 or reduce power to *_50% RATED POWER.

Proposed Amendment 181a TS B3.10-9 09/18/2002

DE.1 Ifthe required actions cannot be completed within the associated completion time, then the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to a HOT SHUTDOWN within six hours. The allowed completion time is reasonable, based on OPERATING experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.

Proposed Amendment 181a TS B3.10-10 09/18/2002

ATTACHMENT 4 To Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated September 18, 2002 Proposed Amendment 181 a Affected TS Bases Pages:

TS B3.10-9 TS B3.10-10 TS B3.10-11

B.1, B.2, B.3, and B.4 When more than one IRPI per group fail, additional actions are necessary to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are limited. Placing the Rod Control System in manual ensures unplanned rod motion will not occur. Together with the indirect rod position determination available via core instrumentation will minimize the potential for rod misalignment. The immediate completion time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this condition.

Monitoring and recording reactor coolant T8,g ensures that significant changes in power distribution and SDM are avoided. The once per hour completion time is acceptable because only minor fluctuations in reactor coolant system temperature are expected at steady state plant OPERATING conditions. The position of the rods may be determined indirectly by use of the core instrumentation. Verification of control rod position once per eight hours is adequate for allowing continued full power operation for a limited 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time provides sufficient time to troubleshoot and restore the IRPI system to operation while avoiding the plant challenges associated with the shutdown without full rod position indication. Based on OPERATING experience, normal power operation does not require excessive rod movement. If one or more rods has been significantly (> 24 steps) moved, the required action of C.1 and C.2 below is required.

C.1 and C.2 These required actions clarify that when one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the position was last determined, the required actions of A.1 and A.2, or B.1, as applicable, are still appropriate but must be initiated promptly under required action C.1 to begin verifying that these rods are still properly positioned, relative to their group positions. If, within four hours, the rod positions have not been determined, thermal power must be reduced to <50% RATED POWER within eight hours to avoid undesirable power distributions that could result from continued operation at > 50% RATED POWER, if one or more rods are misaligned by more than 24 steps. The allowed completion time of four hours provides an acceptable period of time to verify the rod positions.

D.1.1 and D.1.2 With one demand position indicator per bank inoperable, the rod positions can be determined by the IRPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the individual rod position indicators are OPERABLE and the most withdrawn rod and the least withdrawn rod are: < 12 steps apart when RTP is > 85 percent, and < 24 steps apart when RTP is < 85 percent within the allowed Completion Time of once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is adequate.

D.2 Reduction of THERMAL POWER to _50% RATED POWER puts the core into a condition where rod position is not significantly affecting core peaking factor limits. The allowed Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provides an acceptable period of time to verify the rod positions per Required Actions D.1.1 and D.1.2 or reduce power to *50% RATED POWER.

TS B3.10-9

E.1 If the required actions cannot be completed within the associated completion time, then the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to a HOT SHUTDOWN within six hours. The allowed completion time is reasonable, based on OPERATING experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.

TS B3.10-10

Inoperable Rod Limitations (TS 3.10.q)

One inoperable control rod is acceptable provided the potential consequences of accidents are not worse than the cases analyzed in the safety analysis report. A 30-day period is provided for the reanalysis of all accidents sensitive to the changed initial condition.

Rod Drop Time (TS 3.10.h)

The required drop time to dashpot entry is consistent with safety analysis.

Core Average Temperature (TS 3.10.k)

The core average temperature limit is consistent with the safety analysis.

Reactor Coolant System Pressure (TS 3.10.1)

The reactor coolant system pressure limit is consistent with the safety analysis.

Reactor Coolant Flow (TS 3.10.m)

The reactor coolant flow limit is consistent with the safety analysis.

DNBR Parameters (TS 3.10.n)

The DNBR related safety analyses make assumptions on reactor temperature, pressure, and flow.

In the event one of these parameters does not meet the TS 3.10.k, TS 3.10.1 or TS 3.10.m limits, an analysis can be performed to determine a power level at which the MDNBR limit is satisfied.

TS B3.10-11

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