ML20012F352

Suppls Response to NRC 891215 Ltr Re Deviations Noted in Insp Rept 50-440/89-26.Corrective Actions:Profile of Heat Generation from Stored Fuel Vs Time for First Four Fuel Load Discharges Calculated & Design Changes Implemented

ML20012F352
Person / Time
Site:	Perry
Issue date:	04/02/1990
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1161, NUDOCS 9004110219
Download: ML20012F352 (4)

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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY P.O.DOX97 9 P(MRY. OH60 44D61 S THE PHONE @tti)#f43787 8 ADDNEbb10 OLNTIR h0AD FM0ld OLD'rLAND 476 tHtD G TrLEM: to1tes ANSWEMaaiOK: CEIPRVO A\ Kbp\an Sewing The Best location in the Nation PERRY NUCLEAR POWER PLANT w a anoro.m April 2, 1990 I PY-CEI/NRR-ll61 L U.S. Nuclear Regulatory Commission Document Control Desk  !

Washington, D. C. 20555 Perry Nuclear Power Plant i Docket No. 50-440 Supplemental Response to Notice of Deviation 50-440/89026-01 r

Centlement i This letter provides supplemental response to the Notice of Deviation contained within Inspection Report 50-440/89026 dated December 15, 1989, i

The request for the necessary supplemental information was discussed in detail at a meeting with Mr. Mark Ring and others of your staff on February 9, 1990. This information is provided in the attachment to this letter, with changes to the original reponse (reference our letter PY-CEI/NRR-lll6 L, dated January 16,

(

1990) identified by revision bars in the right margin.  ;

Please feel free to call if there are any additional questions.

i Ve tru ours, l i

I Al Kaplan j Vice President  !

Nuclear Group i

AKinje  !

Attachment i I

cet T. Colburn I I

P. lliland R.C. Knop - USNRC, Region III ,

USNRC, Region III ,

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. s j Attachment 1 PY-CEI/NRR-1161 L l Page 1 of 3 l

50-440/89026-01 Restatement of Deviation Perry Nuclear Power Plant Updated Safety Analysis Report, Revision 1, dated ,

March 1989, Section 9.2.2.3 stated that the Unit 2 emergency closed cooling system is used as the Seismic Category I backup cooling vater supply to the fuel pool heat exchangers. Further it was stated that (1) "The Unit 2 emergency closed cooling system vill be available to provide fuel pool heat '

exchanger cooling water prior to Unit i refuelingl" and (2) "Any time after the start of emergency closed cooling system operation, cooling may be restored to the fuel pool heat exchangers by remote-manual action from the control room." '

Contrary to the abovel (1) the Unit 2 emergency closed cooling system was not -

available to provide fuel pool heat exchanger cooling vater prior to Unit I refueling, and (2) the system cross-connect from Unit i emergency service water (current Seismic Category I backup) vas not capable of being placed in service by remote-manual action from the control room. As identified in t System Operating Instructions (SOI)-G41, " Fuel Pool Cooling and Cleanup System," Revision 6, dated December 30, 1988, and SOI-P45/49, " Emergency Service Vater and Screen Wash Systems," Revision 0. dated August 22, 1989, the ,

method utilized to provide a backup Seismic Category I source of fuel pool ,

heat exchanger cooling was expected to take 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to implement. In addition, those instructions required the selected Unit 1 emergency service water locp to be drained in order to remove " blind flanges." Draining of the selected Unit 1 emergency service water loop would make that loop incapable of performing other intended safety functions.

Background and Reason for Deviation l

The Perry Nuclear Power Plant was originally designed as a twin unit facility with specific support systems common to both operating units. For example, Unit 2 Emergency Closed Cooling (ECC) was intended to support the operation of Unit 2 as well as providing backup cooling water to the fuel pool heat exchangers during loss of normal cooling flov from the Nuclear Closed Cooling System. Prior to receipt of the Unit 1 Operating License in 1986, construction of Unit 2 was indefinitely postponed and the Unit 2 ECC System was not completed. Design changes were made to enable Unit 1 Emergency Service Vater (ESV) to be cross-tied into Unit 2 heat loads so that a safety related source of cooling water was available for the fuel pool heat exchangers. Design calculations were performed to ensure that Unit 1 ESV could supply enough cooling water to the fuel pool heat exchangers while still maintaining flow through the normal flow paths. At that time, i t was stimated that the Unit 2 ECC System would be completed before spent f' el was introduced into the pools in the Unit 1 first refuel outage (RFO-1). A change to the Perry Final Safety Analysis Report (FSAR) was processed in Amendment 17, effective March 6, 1985, that indicated the fuel pool heat exchanger cooling vater would be supplied from Unit 1 ESV prior to Unit 2 operation.

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Attachment 1 i PY-CEI/NRR-ll61 L l Page 2 of 3 l l

l Although all necessary evaluations regarding heat removal capabilities of the ESV system had been performed to support the decision to suspend construction I of the Unit 2 ECC system, the original FSAR text which ctated that the Unit 2 I ECC system would be available to provide fuel pool heat exchanger cooling water prior to Unit I refueling was not deleted from the FSAR in Amendment 17 due to an oversight.

Commitments made in licensing documents and other regulatory correspondence are tracked by a computer based commitment tracking system (Perry Regulatory Information Hanagement System (PRIMS). Currently, procedures are in place to direct those responsible for such documents to enter commitments into PRIMS tt the commitments are made. Additionally, a comprehensive effort was undertaken prior to plant licensing to review the FSAR, and ensure that all statements of commitment vere properly identified for further tracking. During the efforts, apparently, the statement regarding the completion of Unit 2 ECC prior to Unit '

I refueling was not input to the system as required.

Prior to the first refueling outage, the database was searched for all "

commitments related to the outage, in order to properly schedule activities and ensure commitments were satisfied. As a result of the omissions mentioned above, the potential deviation vent undetected.

Section 9.2.2 of the Updated Safety Analysis Report (USAR) provides a description of the Emergency Closed Cooling System which details the capability to restore fuel pool cooling from Unit 2 ECC by remote-manual action from the control room. This statement is not intended to imply that the alternate cooling systems vill provide the same feature. Remote-manual action from the control room is not considered a design requirement for the alternate cooling supply to the fuel pool heat exchangers.

Corrective Actions Taken and Results Achieved The present plant spent fuel pool heat loads were physically measured during

! RFO-1 to cause the fuel pool temperature to increase at a rate of 4 degrees l Fahrenheit per day while fuel pool cooling and cleanup was out of service.

Without alternate cooling measures, a loss of normal cooling would cause the normal spent pool temperatures (approximately 95 degrees F) to increase to the the alarm setpoint (127 degrees F) in approximately eight days. Equipment operation is not affected until 150 degrees F is reached; this would occur in another five to tix days. The total result is that it vould take approximately 14 days, with no actions taken, for pool temperature to increase to consequential temperatures. As a function of fission product decay, the current heat input is even further reduced, providing an added measure of  :

conservatism. '

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. . - s Attachment 1

' I PY-CEI/NRR-1161 L Page 3 of 3 ,

The transfer to Emergency Service Vater System backup cooling, as described in System Operating Instructions (SOI-G41) " Fuel Pool Cooling and Cleanup System" and SOI-P45/49, " Emergency Service Vater and Screen Vash Systems", involves ,

draining the system to reverse spectacle flanges, and was demonstrated during the Startup Testing Program to take approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, adequate time exists to implement the procedure prior to reaching excessive pool temperatures. Additionally, for the current conditions, adequate time exists to implement other alternate cooling measures (such as system bleed and feed, fill and drain or use of temporary external cooling systems) if conditions do not allow the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shutdown of the Unit 1 ESV System. '

In Mder to correct the erroneous statement in the USAR, a change vas processed and became effective in March, 1990. This change only removed the references to the Unit I refueling, since the initial refueling outage has already been completed. The change ves not intended to replace the need for  ;

the additional evaluations discussed below. ,

Corrective Actions to Avoid Further Deviations corrective actions also included the calculation of a profile of heat generation fro.n stored fuel versus time for the first four fuel load discharges. Follovup engineering evaluation has identified that engineering design changes vill be necessary to provide adequate backup cooling for the spent fuel pools after the second-cycle core offload. When completed this engineering evaluation vill recommend the necessary engineering design and/or procedural modifications. As applicable, the necessary modifications vill be '

developed and implemented on a schedule appropriate to support the second refueling outage. Additionally, the USAR vill be modified to accurately represent plant configuration.

In order to ensure that the Safety Analysis Report accurately reflects plant design, and that other statements of commitment were not inadvertently overlooked, the USAR is being reviewed to identify all Unit 1 initial refueling outage commitments related to Unit 1-Unit 2 interface. This review is expected to confirm that the omission of this item from the commitment tracking system was an isolated occurrence.

D_ ate When Corrective Actions Vill Be Completed The engineering evaluation to determine necessary modifications and the USAR review are expected to be completed by May 30, 1990. Upon completion, a supplemental response vill be provided detailing the results of the evaluations and review activities. In addition, the proposed schedule for completion of additional necessary corrective actions vill be provided at that time. It is currently expected that all corrective actions vill be completed as necessary to support the second refueling outage, scheduled to begin approximately September 1990.

NJC/ CODED /3288