ML19354E788

Application for Amend to License NPF-58,revising Tech Spec Table 3.3.2-2, Isolation Actuation Instrumentation Setpoints, RCIC Equipment Room Differential temp-high Trip Setpoint & Allowable Value.Meeting W/Nrc Requested

ML19354E788
Person / Time
Site:	Perry
Issue date:	01/26/1990
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19354E789	List: ML19354E788 ML19354E791
References
PY-CEI-NRR-1127, NUDOCS 9002010339
Download: ML19354E788 (5)

Text

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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY P.O. BOX 97 3 PERRY. OHIO 44001 3 TELEPHONE (216) 2 4 3737 - 5 ADDRESS 10 CENTER ROAD FROM CLEVELAND: 479 wits 0 3 TELEX: 241699 ANSWER 9ACK: CElPRYO  ;

Al Kaplan Serving The Best location in the Nation t PERRY NUCLEAR POWER PLANT i gj$"$ i January 26, 1990 PY-CEI/NRR-1127 L {

U.S. Nuclear Regulatory Commission  ;

Document Control Desk Wohington, D. C. 20535 i

Perry Nuclear Power Plant -

Docket No.' 50-440 Emergency Technical Specification-Change Request - Revision of RCIC Differential. Temperature-High Isolation Setpoint and Allowable Value Centlemen:  ;

i l The Cleveland Electric Illuminating Company (CEI) hereby requern amendment of j Facility Operating License NPF-58 for the Perry Nuclear Power M att. Unit 1. 1 In accordance with the requirements of 10CFR50.91(b)(1), a cott of this  :

request for amendment has been sent to the State of Ohio as~ indicated below.

I This letter requests revision of Technical Specification 3.3.2 " Isolation' '

Actuation Instrumentation. The-change to Specification 3.3.2 will revise the RCIC Equipment Room Differential Temperature-liigh Trip Setpoint and Allowable i Value, and will affect Technical-Specification Table 3.3.2-2.

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It is requested that this proposed amendment be processed under the' emergency 1 situation clause provided in 10CFR50 91(a)(iii)(5). Under the present plant.- [

situation, until such time as the differential temperature instrument i setpoints are revised, the RCIC system is. considered. inoperable in'accordance~ '{

with Technical Specification 3.7.3. As such the Perry Nuclear Power Plant'~

j would be required to commence a-plant shutdown by February 1, 1990.-

Due to the submittal of this request, our January 19.-1990 emergency change- i letter (PY-CEI/NRR-1124L)-which requested removal of this isolation function  !

from the Technical Specifications, should continue to be reviewed by the NRC  !

but should be reviewed under the normal process rather than emergency. .CE1:

believes the removal of the potential for unnecessary isolations of the RCIC' '

system when it is being called upon to restore reactor water level is the-s proper and prudent path to follow in order to maximize the safety of the. ,

-plant. The approval of revised setpoints for this isolation function is- ,

viewed only as an interim measure while the NRC continues to reiiew the .

January 19, 1990 proposal.

9002010339 900126 PDR p

ADOCK 05000440 PDC

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. USNRC January 26, 1990 PY-CEI/NRR-ll27 L Attachment 1 includes the Summary / Safety Analysis, the Statement of Emergency Situation, the No Significant Hazards Consideration and the Environmental Consideration. Attachment 2 includes the proposed markup of the changed Technical Specification page.

The revised setpoint and allowable value provided in Attachment 2 to this ,

le

$$gterarevalidfortheperiodoftimeuntilLakeErietemperaturesriseto F. In the interim, CEI requests the opportunity to meet with the NRC  ;

technical staff to further discuss futute options including the change .

requested by our January 19, 1990 letter.

If you have any questions, please call.

l Very trul ours,  :

d Al Kap an j Vice President '

Uuclear Group ,

l' AKinic  !

Attachments cc: T. Colburn P. Hiland USNRC Region III J. Harris (State of Ohio)

4 -

• ' Attcchment 1

• PY-CEI/NRR-ll27 L Page 1 of 3 Summary / Safety Analysis The purpose of this License Amendment Request is to propose a change to the Perry Nuclear Pover Plant (PNPP) Technical Specification (TS) 3.3.2 " Isolation Actuation Instrumentation", Table 3.3.2-2. This Table lists various Isolation Actuation setpoints and allovable values. The proposed change vould temporarily revise the Reactor Core Isolation Cooling (RCIC) Equipment Room Differential Temperature (delta-T) -High Setpoint and Allovable Value. This change is being made on an emergency, temporary basis for the vinter months, in order to avoid unnecessary isolations of RCIC during system operation with no steam leaks present.

The previously submitteu change request letter dated January 19, 1990 (PY-CEI/NRR-ll24 L) presented detailed descriptions of the recent RCIC isolation and the parameters that led to the event, including a design description of the RCIC room coolers and the effects that the cold vinter temperatures have on the Emergency Closed Cooling (ECC) vater supplied to the RCIC Room Cooler cooling coils. That letter also presented the basis for retention of the delta-T alarm function to provide a diverse method of RCIC steam line leak detection with subsequent operator action to isolate if necessary, and the basis for removal of the isolation function in order to maximize availability of this desirable water addition system during transients involving the need to restore reactor water level. The Cleveland Electric Illuminating Company intends to continue to pursue approval of this previous request on a non-emergency basis since it seems the more appropriate, prudent course of action to take when balancing the two safety concerns involved maintenance of reactor vessel vater level versus a possible small steau.'oreak which can still be detected and isolated either manually or autcmatically by the remaining controls.

However, due to initial NRR feedback on the original proposal, CEI has considered what other options are available to optimize RCIC availability for the next several vinter months while discussions continue on the original proposal. These considerations led to the development of a new setpoint for the delta-T isols, tion which is more appropriate than the setpoint currently provided. This setpoint (and allowable value) bound the range of conditions which might be experienced during any operational transients or accidents from the present time until lake temperatures reach 55"F, which usually occurs in early Hay. The setpoint was chosen with margin to allow for normal RCIC system operation under these vinter conditions, while still retaining the capability to detect and isolate leaks in the lover range of crack sizes.

The current Technical Specification delta-T setpoint number was based on i assumptions of room cooler efficiency under hottest summer lake temperatures I and post-small-break-LOCA plant heat loads on the ECC cooling vater, therefore Engineering performed entirely new sets of calculations to bound the current vinter conditions. One decision that was made and factored into the calculations was that the ECC outlet valve to the room cooler vould no longer be throttled in the vinter, due to concerns about fluctuations in ECC system flow rates with the valve throttled down to an almost closed position, and concerns that even minor changes in the valve position (from any cause) could result in a large percentage change in the flow rate through the cooler and J

T'

','* Attcchment 1 PY-CEI/NRR-ll27 L Page 2 of 3 could invalidate any calculations. Engineering then performed several bogndingsteamleakcasesincludinga" cold"casewithlaketemperatureat 33 F and no heat loads on ECC other than the RCIC room cooler, and a " cool" case with lake temperature at 55 I' and maximum post-small-break LOCA plant heat loads on ECC such as the control complex chiller units. These calculations address these bounding conditions, and also consider the RCIC room arrangement and its interconnections with adjoining rooms, heat sinks such as valls which absorb heat from the released steam, pressurization . _i effacts and HVAC impacts. The results of thase bounding cases vere analyzed and the optimal setpoint for these conditions was chosen and is provided in t)e attached Tech Spec page markup (See Attachment 2). Although CEI believes d' more appropriate to depend on detection of small leaks with the combination of delta-T alarm / manual isolation and ambient temperature sensor / automatic jsolation, as proposed in our original change request, it is felt that the proposed setpoint will be acceptable for the interim time period.

Statement of Emergency Situation See discussion in the January 19, 1990 letters the circumstances leading to the need for emergency relief have not changed.

No Significant Hazards Consideration The Nuclear Regulatory Commission (NRC) has promulgated standards in 10CFR50.92(c) for determining whether a proposed amendment to a facility operating license involves no significant hazards consideration. A proposed amendment to an ope ating license involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment vould nots (1) Involve a significant increase in the probability'or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind ot accident than previously evaluated; or (3) Involve a significant reduction in a margin of safety.

CEI has reviewed the proposed amendment with respect to these standards and has determined that the proposed changes do not-involve a significant hazard because:

(1) The proposed change does not involve a significant increase in the probability or consequences of a previously evaluated accident.

The differential temperature isolation inotrumentation provides monitoring for leaks. Therefore, the probability for leak, initiation is not affected by the revision of_the~ delta-T isolation setpoint. 4 I

il Attechment 1 .l PY-CEI/NRR-1127 L j Page 3 of 3 1 i

The consequences of a previously evaluated accident also have not -]'

changed. The range of possible RCIC steamline breaks (up to and including a circumferential steamline break) is not affected.by this proposed thange. The leak detection isolation actuation  ;

instrumentation and alarms cover a vide range of steam piping breaks including both small leaks and large breaks in the RCIC line. As i such any significant. leak in the RCIC room vill continue to be j sensed by redundant and diverse instrumentation with appropriate i setpoints for alarm and/or isolation capability. As such the consequences of a RCIC steamline break vill not change, and are ,

still bounded by the steamline break outside of containment scenario l analyzed in USAR Section 15.6.4. Thus, the consequences of a i previously evaluated accident have not changed.  !

(2) The proposed change does not create the possibility of a new or i iifferent kind of accident from any accident previously evaluated.

As stated above the differential temperature isolation actuation instrumentation is a monitoring system. Revision of the isolation  ;

setpoint of this monitoring system cannot create a new type of i accident, since breaks of the RCIC steamline, up to and including a )

circumferential break, are bounded by other accidents presently analyzed in USAR Section 15.6.4.  !

, (3) The proposed change does not involve a significant reduction in the 1

margin of safety. There vill still exist sufficient redundant and l diverse leak detection instrumentation with appropriate setpoints to

! detect steam leaks / breaks in the RCIC area. This change does not ,

4 therefore affect any accident analysis nor does it have any effect "

on performance characteristics of safety systems. As such it vill  :

not result in a reduction in the margin of safety. Also,,since this change vill increase the reliability of the RCIC system'by reducing )

. the possibility of an unnecessary isolation of RCIC vhen it is-being l called upon to restore reactor vater level, overall plant safety vill be slightly increased. ,

Environmental Consideration ,

l l See discussion in the January 19,'1990 letters the environmental consideration >

conclusion has not changed.

a l

NJC/ CODED /3101

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