ML20073G201
| ML20073G201 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/21/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20073G187 | List: |
| References | |
| NUDOCS 9410040043 | |
| Download: ML20073G201 (5) | |
Text
gi# "%,?g UNITED STATES 8 CfE 5
NUCLEAR REGULATORY COMMISSION
\\.Ey [/ !
WASHINGTON, D.C. 20555 4 001
/
SAFETY EVALUATION BY THE OFFICE OF NVCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
66 TO FACILITY OPERATING LICENSE NO. NPF-58 THE CLEVELAND ELECTRIC ILLUMINATING COMPANY. ET AL.
PERRY NUCLEAR POWER PLANT. UNIT NO. 1 DOCKET N0. 50-440
1.0 INTRODUCTION
By letter dated March 19, 1992, the Cleveland Electric Illuminating Company, et al. (licensees), proposed changes to the Technical Specifications (TSs) for the Perry Nuclear Power Plant, Unit No. 1.
This amendment includes 10 administrative changes. The changes include:
clarifying the applicability of TS 3.0.4, eliminating potentially misleading clarification of core alteration, clarifying the operability requirements for reactor vessel level accident monitoring, adding Operational Condition 2 to the requirements for evaluating the effect on structural integrity of the reactor coolant system, if chemistry is out of limits, correcting a typographical error associated with the feedwater leakage control system, clarifying the acceptable range for containment humidity, conservatively changing the setpoint for secondary containment vacuum, clarifying what actions are required when 1 of 2 inoperable diesel generators has been restored to operability, clarifying the required number and location of the proximity sensors and level monitoring instrumentation associated with the inclined fuel transfer system (IFTS), and eliminating reporting requirements that conflict with 10 CFR 50.4.
These ten administrative changes will ensure consistency of definitions, actions, and setpoints between various TS sections, the Updated Safety Analysis Report (USAR) and 10 CFR Part 50.
In addition to the ten changes requested by the licensee, additional pages were changed, as described in section 2.11 to correct identified errors.
2.0 EVALUATION Each change will be discussed separately.
2.1 APPLICABIllTY OF TS 3.0.4 For TS 3.3.1 ACTION a. and TS 3.3.2 ACTION b. the proposed change is the deletion of statement that TS 3.0.4 does not apply. As a consequence of Generic Letter 87-09, Amendment 30 deleted the requirement to specify in applicable TS when TS 3.0.4 did not apply. However, the two deletions requested for TS 3.3.1 and TS 3.3.2 were not originally submitted with the other changes requested for Amendment 30.
TS 3.3.1 Action a. gives specific directions to place inoperable channels of the reactor protection system in one trip system in-trip unless placing the channel in-trip would cause the Trip Function to occur.
Similarly TS 3.3.2 ACTION b. gives specific directions to place inoperable channel (s) of one isolation actuation trip h
P
f
. system in a tripped condition within one hour unless placing the channel (s) in a tripped condition would cause the Trip Function to occur.
Both of these TS are footnoted to specify restoring a channel to operability in two hours or take the actions associated with loss of a trip function. Therefore, the change deletes the statement TS 3.0.4 does not apply.
As discussed in GL 87-09, TS 3.0.4 does not apply if the TS permits continued operation for an unlimited period of time, or allows entry into an operational mode or other specified condition of operation.
Therefore, these deletions are in accordance with the guidance of GL 87-09.
Another change requested restores the statement, "The provisions of Specification 3.0.4 are not applicable." to Action 38 associated with Table 3.3.3-1, " Emergency Core Cooling System Action Instrumentation Action." This requirement was deleted with Amendment 30.
The basis for restoring the statement is that Action statement 38 does not allow an unlimited period of time, but states that one of two channels can be placed in-trip until the next channel functional test.
The surveillance requirements for channel functional tests is monthly. However, the purpose of GL 87-09 was not to restrict mode changes if the action requirements provide an acceptable level of safety for continued operation.
Therefore, the staff agrees with restoring the exception.
The staff notes that the improved Standard Technical Specifications (STS), when approved for Perry, will eliminate the need for the new TS 3.0.4 statement.
2.2 CORE ALTERATION DEFINITION CLARIFICATION The TS amendment requests deletion of the asterisk and associated footnote for ACTION 3 and ACTION 9 in Table 3.3.1-1, " Reactor Protection System Instrumentation." The f ootnote explains that the replacement of local power range monitor (LPRM) strings need not be suspended when all operations involving CORE ALTERATIONS are suspended.
This footnote leads to confusion since the definition of CORE ALTERATIONS specifically excludes normal movement of LPRMs.
Removing this footnote is consistent with TS 3.9.2 which does not specify any additional restrictions on the source range monitors during replacement of LPRM strings.
This is strictly an administrative change.
2.3 REACTOR VESSEL WATER LEVEL INSTRUMENTATION The change requests additional information be added for the BWR Accident Monitoring reactor coolant level instrumentation (Table 3.3.7.5-1) to include both wide range and fuel zone instrumentation operability and surveillance requirements. This change is for clarification and does not change the intent or requirements for the reactor vessel level instrumentation.
2.4 ADDITIONAL OPERATIONAL CONDITION ADDED TO CHEMISTRY RE0VIREMENTS This change is to provide clarification to Specification 3.4.4., ACTION c.
the intent of ths last sentence of ACTION c. is to ensure that, in the event an engineering evaluation is relied on to justify continued plant startup from Operational Condition 4 or 5, with an out-of-limit conductivity, pH or chloride concentration, that the engineering evaluation is completed and the effects on the structural integrity of the reactor coolant system are
determined acceptable for continued operation prior to entering a higher mode of operation. Under the existing wording of ACTION c., a mode change to Operational Condition 3 is not allowed until the engineering evaluation is performed and an acceptable determination obtained. However, the ACTION statement fails to extend this requirement to mode changes to Operational Condition 2.
It is typical for a BWR, during the performance of a plant startup, to move from Operational Condition 4 to Operational Condition 2, without entering Operational Condition 3 at any time. Therefore, the proposed change to ACTION c. will make it clear that mode changes into either i
Operational Condition 2 or 3 are not allowed, until it is determined that the structural integrity of the reactor coolant system remains acceptable for continued operation.
2.5 CORRECT DISCREPANCY IN ACTIONS FOR FEEDWATER LEAKAGE CONTROL SYSTEM The proposed change in the ACTION statement for Specification 3.6.1.9 will require restoration of an inoperable feedwater Leakage Control System within 30 days or require being in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Currently the action statement requires restoration within 30 days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The revised wording 4
requested by the licensee replaces "or in COLD SHUTDOWN..." with "and in COLD SHUTDOWN..." is consistent with the original intent of this specification and with that of other standard TS ACTION statements.
2.6 CONTAINMENT AVERAGE TEMPERATURE AND RELATIVE HUMIDITY RELATIONSHIP The requested change will extend the line on Figure 3.6.5.2-1, which divides the regions of acceptable versus unacceptable operation for containment relative humidity as it relates to the containment average temperature.
Currently, the Figure does not provide any criteria for acceptable versus unacceptable when the average containment air temperature is below 74 *F.
Since the containment temperature can go below 74 *F, the extension of the line to 0% relative humidity at or below 62 *F eliminates concern about the need to maintain humidity levels.
The intent of the figure is to show initial relative humidities at various containment temperatures which are acceptable in order to maintain peak vacuum inside containment s 0.72 psi (design is 5 0.80 psi) following initiation of both containment spray loops. Additional engineering evaluations indicate that extending the line is conservative.
The staff notes that the submittal to revise TS to the improved STS, PY-CEl/NRR-1732 L, dated December 16, 1993, requests deleting the figure and including the information in the TS bases.
2.7 INCREASE VACUUM RE0VIREMENTS FOR SECONDARY CONTAINMENT PNPP's design bases and safety analysis require the secondary containment (annulus area) to be maintained at a minimum negative pressure of 0.25 inches water gauge at all times.
The licensee requests the value of vacuum in TS 4.6.6.1 be increased to 0.66.
As a result of NRC Information Notice 88-76,
F
. "Recent Discovery Of a Phenomenon Not Previously Considered In The Design of Secondary Containment Pressure Control," engineering calculations were revised to address the differences between outside air and annulus air and sensor locations being 170 feet below the top of secondary containment.
Based on the new calculations, the analytical setpoint required to maintain the minimum negative pressure of 0.25 inch vacuum water gauge was determined to be 0.66 inches water gauge post LOCA and 0.50 inches water gauge during normal minimum design environmental conditions.
Calculations to establish new field setpoints for delta-P and for secondary containment air flow values based on the new analytical setpoint were completed and the new field setpoints were incorporated into procedures and the Safety Analysis Report (SAR) was revised.
To ensure consistency between the revised analysis, the SAR, and the TS, the values included in the TS will be changed to the more conservative values.
2.8 CLARIFICATION OF ACTIONS FOR RESTORING DIVISION 1 AND DIVISION 2 DIESEL GENERATORS The change to TS 3.8.1.1 clarifies the actions to take if one diesel generator is declared OPERABLE after both Division 1 and Division 2 diesel generators have been inoperable.
ACTION g. contains the requirements and time constraints for returning first one, and then both of the Division 1 and 2 diesel generators.
The change clarifies that ACTION e. shall be performed after the first diesel generator is restored. ACTION e. requires that within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> a verification be m de for all systems, subsystems, trains, components, and devices that depend on the restored diesel generator as a source of emergency power. This TS change is for clarification and neither adds or removes any requirements.
2.9 IFTS SPECIFICATION AND SURVEILLANCE REOUIREMENTS The change requested clarifies the LIMITING CONDITION FOR OPERATION (LCO) and Surveillance Requirements for the IFTS proximity sensors and liquid level sensors.
The IFTS has 2 proximity sensors at 12 separate carriage positions.
The change will ensure that at least 1 of the 2 proximity sensors at each of the 12 carriage positions shall be OPERABLE.
Similarly, the clarification will ensure that at least 1 of the 2 liquid (water) level sensors will be OPERABLE at each of the two monitoring locations or positions (the " Tube full" and the " Tube Empty" positions).
2.10 CONSISTENCY OF TS SECTION 6.9 AND 10 CFR 50.4 RE0VIREMENTS The changes requested remove inconsistencies between the administrative reporting requirements (where to send reports and who to send the reports to) included in the TS and the requirements of 10 CFR 50.4.
When 10 CFR 50.4 was revised, it specifically stated that its requirements took precedence over any existing TS requirement. This is an administrative change only.
2.11 MISCEllANE0US CHANGES Table 3.6.4-1, deleted in Amendment 44, was deleted from Index page xiii.
Table 3.8.4.1-1, deleted in Amendment 44, was deleted from Index page xv.
Index page xx was corrected for TS 3/4.6.1 page numbers.
The second listing for Figure 5.1.1-1 was removed on Index page xxiv.
Entries for TS 6.2.1 and 6.2.3 on page xxv were changed to agree with the TS and page entries a
f
~
corrected.
Entry for TS 6.9.2 on page xxvi was corrected. The title " CONTROL R0D SCRAM MAXIMUM INSERTION TIMES," was corrected to read " CONTROL R0D MAXIMUM SCRAM INSERTION TIMES" on page 3/4 1-6.
On page 3/4 8-2 in Action c. "with" changed te "within" in last sentence. On page 3/4 9-19 in TS 4.9.12.2 "in in" was changed to "is in" in the second line.
Page B 3/4 6-1 was changed to insert the word " primary" before " containment leakage" to agree with the TS title. The footnote on TS page 3/4 8-21 was changed from "**" to a single Page B 3/4 6-1 was changed to correct the title of 3/4.6.1.2 in the BASES section to " Primary Containment Leakage" to agree with the TS. All of these changes are made for clarity and accuracy.
2.12 RESULTS OF REVIEW The NRC staff has reviewed the ten proposed changes to the TS and based on the evaluations performed, the NRC staff finds the proposed changes to be acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes a surveillance requirement.
The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (57 FR 30260).
The amendment also changes a reporting or recordkeeping requirement. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
Linda Gundrum Date: September 21, 1994
-