ML20079L266
| ML20079L266 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/30/1991 |
| From: | CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20079L259 | List: |
| References | |
| PY-CEI-NRR-1389, NUDOCS 9111060191 | |
| Download: ML20079L266 (11) | |
Text
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PY-CEI/NRR-1389 L Page 1 of 11
MMARY This Technical Specification change request is being submitted to clarify the logic for the instrumentation used to isolate the liigh Pressure Core Spray (llPCS) Test Return Valve (IE22-F023) and to initiate the HPCS system, and to identify the appropriate actions to be taken when one or mare of the reactor vessel level-instruments (Level 2 or Level 8) or the l'igh dryvell pressure instruments for the llPCS logic become inoperable.
These changes are accessary because the present wording in both Table 3.3.2-1 and 3.3.3-1 can be confusing and cause compliance problems. Compliance with the Table 3.3.2-1 Actions could also result in the loss of the isolation fun: tion of a containment isolation valves therefore these changes provide an improvement in plant safety.
The changes belag submitted consist of the following:
Based on the isolation logic involved with containment isolation valve lE22-F023, the llPCS Test Return Line isolation valve, several changes to the specifications are necessary.
As presently worded, Specification 3.3.2 requires no operator actions with up ti tvc of the Reactor Vessel Vater Level-Low Level 2 or the Dryvell Pressure-liigh inst ruments, inoperable.
Depending on which instruments are inoperable, a loss of the isolation function to the IE22-F023 valve may occur without any action required by the Technica) Specifications. This is neither conservative nor appropriate. Therefore, the Technical Specification Table 3.3.2-1 is being amended to assure that action is required if any of the water level or dryvell pressure isolation instruments for the IE22-F023 valve become inoperable.
Since this isolation logic is l
s'9ociated only with the one valve, which is a Division 3 (HPCS) valve, it was decided that the appropriate revision vould be to include two new line items in Section 1 of Table 3.3.2-1 (Item 1.b for Reactor Vessel Vater Level-Lov Level 2 (Division 3) and Item 1.d for Dryvell Precsure-liigh (Division-3)), and to rename the present Reactor Vessel Level-Lov Level 2 and Dryvell Pressure-High functions to signify that they are Division 1 and 2 instruments, and finally to add Note (1) to clarify that the Division 3 vater level and dryvell pressure instruments tt:at isolate this salve consist of only one trip system with four channels logically combined-in a one-out-of-two-taken-tvice configuration.
Similarly, since the Division 3 Hanual Initiation isolation logic is associated only with this a valve, o new line item has been added (Item 1.h for Manual Int.'ation (Division 3)), and the pr(sent Hanual Initiation line ite; & s been renamed to signify that the associated instruments are Division 1 and 2, and finally Note (m) has been added to clarify 1
that the Division 3 Hanual Initiation instrument consists of a single channel in a single trip systeni.
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4 Page 2 of 11 2.
The above described isolation logic for 1E22-F023 is the only Division 3 Isolation Actuation logic, therefore, the ACTION for inoperable instrumentation should be different than for Division 1 and 2.
Presently these Division 3 instrursents are combined with the Division 1 and 2 instruments as discussed above. The requirsd Table Artion for these instruments is presently ACTION 20 which requirer the plant to be plac'd in HOT SHUTDOVN vithin 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> under certain conditions.
Since the Division 3 instruments only supply isolation instrumentation to the HPCS Test Return Line isolation valve, and this valve can be isolated without affecting the OPERABILITY of the HPCS system, ACTION 28 is the more appropriate ACTION.
3.
An editoriel charge (the addition of a comma) is being made to ACTION 28 to help clarify that one of the requirements vhan entering ACTION 28 is to declare the affected system inoperable regardless of which other option for securing the penetration is taken. Vithout the comma it could be misinterpreted that the affected system needs to be declared inoperable only if the penetration is isolated, but not if tne affected cystems isolation valve is closed, or if the valve-is verified closed by remote indication and is electrically disarmed. Adding the comma makes the inoperability of the affected system an independent action from how the penetration is secured, arJ thus prevents possible confusion.
4.
ACTION 34 on Tech Spec Table 3.3.3-1 "ECCS Actuation Instrumentation" is being revised to remove the reference to "both Trip Systens"-in the ACTION. As with the isolation logie to the 1E22-F023 valve, the ECCS Actuation Instrumentation for Reactor Vessel Level-Lov level 2, High Level 8, and Dryvell Pressure-High have only one logic system, configured in c one-ont-of-tvo-taken-twice arrangement. To attempt to classify this arrangement as two separate trip systems vould not be consistent with the normal
-convention for defining trip systems. Therefore the action is being
. redefined to provide requirements appropriate to one trip system, i.e.,
placing the inoperable channel (s) in trip, or declaring the
.HPCS system inoperable.
In this action, the oporttor has the opportunity to place one or moza inoperable channels in trip if doing so would not cause a HPC9 actuation, or if placing all the inoperable channels in trip would cause an actuation, the operator can declare the HPCS system inoperable (and enter Technical Specification'3.5.1).-
5.
The Action statement associated with the Division 3 Vater Level-digh Level 8 instruments is being corrected such that the required Action to be taken for inoperable instruments vili be the same as that tequired for the Division 3 Vater Level-Lov Level 2 and the Dryvell Pressure-High instruments, which have an identical logic configuration as the Level 8 instruments.
Cumulatively, these changes vill provide a much higher degree of clarity and consistency for the instruments ineclved, while avoiding unnecessary plant shutdown transients due to inappropriate appli:ation of the Action statements
-of the Technical Specifications.
l l
PY-CEI/NRR-1389 L Page 3 of 11 SAFETY ANALYSIS Fach change vill be discussed separately to ensure an understanding of the issues.
- 1. Clarification of the Isolation Instrumentation used to isolate the IE22-F023 valve.
The simplified logic for isolating the High Pressure Core Spray System Test Return Line Valve (IE22-F023) is depicted in two different ways in Figure lA and IB.
It is a single trip system, employing a one-out-of-tvo-taken-tvice logic (except for the Manual Initiation function, which is discussed separately below).
Technical 3pecificction Table 3.6.4-1 indicates that ti lE22-F023 valve is i Group 1 isolation valve. Using this designs.
,n, Technical Specification Table 3.3.2-1 Section 1 indicates that the TRIP FUNCTIONS which operate Group 1 valves are Reactor Vessel Vater Level-Lov Level 2, Dryvell Pressure - High and Manual Initiation. The present HINIMUM OPCRABLE CHANNELS PER TRIP SYSTEM shown in the Technical Specifications for each of these TRIP FUNCTIONS is 2.
As shovn on Figure 1, this means that for the instruments that isolate this particular valve, the literal reading of the current Technical Specification would say that up to two of the instruments for the Reactor Vessel Vater Level-Lov Level 2, and Dryvell Pressure-High TRIP FUNCTION can be inoperable, and the MINIMUM OPERABLE CHANNELS PER TRIP SYSTEM requirement has not been violated.
Presently no actinn is-required by such a literal reading until three or more of the instruments per TRIP FUNCTION are inoperable.
Such lack of action is not considered to ba appropriate. Depending on which instruments are'inopernble, the TRIP FUNCTION could be lost without.ree.uiring any Technical Specification ACTION (see Figure 1A and IB). -This resulted from grouping these instruments with the Division 1 and 2 Group 1 isolation instruments. The instruments used to isolate the 1E22-F023 valve are not vsed to isolate any other Group 1 isolation valve, and do'not usa the same logic s.s the rest of the Group 1 valves (see Figure 2).
In fact, the instruments used to isolate the IE22-F023 valve.are the same instruments and logic that initiate the High Pressura Core Spray system during a Loss of Coolant Accident (LOCA). The :522-F023 valve logic's, primary purpose is to close the valve in order to assure that the HPCS system is properly aligned to send water to the Reactor Vessel. The secondary function is the containment isolation function of the valve (See Figure 3 for a simplified diagram of the HPCS system). To clarify this logic and to require Technical Specification ACTIONS with one or more of the instruments inoperable, the Division 3 instruments are being separated from the Division 1 and 2 instruments by giving them their own lias item in Section 1 of Technical Specification Table 3.3.2-1.
The MINIMUM OPERABLE CHANNELS PER TRIP SYSTEH for the Reactor Vessel Vater Level-Lov Level 2 and Dryvell Pressure-High was changed to 4, with a note added (Note 1) to explain that there is only one trip ssstem.
By making these change;, if one or more b
PY-CEI/NRR-1389 L Page 4 of 11 of the instruments becomes inoperable. ACTION b requirements (or Tech Spec page 3/4 3-9)-vill apply, which requires that either the inoperable channal(s) be placed in the tripped condition, or the ACTION tequired by the Table be taken. The Table ACTION for these Division 3 instruments has been designated as ACTION 28.
This ACTION is more approprir.te for these instruments, since the 1E22-F023 valve can be' isolated (thereby fulfilling-the isolation instruments safety function) without causing the 11PCS system to be physically inoperable.
ACTION 28 does require that the llPCS system be declared inoperable under these conditions, vl.ich places a time limit on the duratinn of the instruments' inoperability. A minor editorial change is being made to ACTION 28 (the addition of a comma) to avoid confusion as to when the affected system must be declared inoperable.
It has always been the intent that the affected system be declared inoperable no matter which of the isolation actions in taken within ACTION 28.
The addition of the comma should clarify this by grammatically separating this requirement from the rest of the requirements within ACTION 28.
Since the ACTION and the intent of the ACTION remains the same, this editorial change has no safety consequence.
In addition, in order to be consistent _vith the separation of the Division 1 and 2 logic from the Division 3 logic as discussed above, a separate line item is being established for the llanual Initiation channel for Division 3.
As shovn in Figures lA and 18 versus Figure 2, the Division 3 Hanual Initiation function for the 1E22-F023 valve also consists of only one trip system versus the two trip systems of the Division 1 snd 2 valves. This one trip system has a single. Manual Initiation channel, which is reflected in the new line item that is being added.
Also, similar to the new line isems for the Vater Level and Dryvell Pressure functions, ACTION 28 is being assigned to the Marual Isolation function for Division 3.
The other changes made to Section 1 of Technical Specification Table 3.3.2-1 are editorial and include the following.
First, the existing letters of the TRIP FUNCTIONS have been changed because of the inclusion of the new Division 3 TRIF FUNCTIONS.
- Secondly, the existing TRIP FUNCTIO 9s for Reactor Vessel Level and Dryvell Pressure have bsc modified to signify these are Division 1 and 2 instruments.
- 2. Changes to Technical Specification Table 3.3.3-1.
During the development of the above described changes to the Isolation Instrumentation for the IE22-F023 valve, it became apparent that changes should also be made to Table 3.3.3-1.
The first change deals with ACTION 34. As presently written, ACTION 34 infers that there are two TRIP SYSTEMS associated with the ilPCS system Reactor Vessel Vater Level - Lov Level 2 and Dryvell Pressure - liigh instrumentr. Ilovever, in actuality the instruments and logic used are the sama as those used for icolating the IE22-F023 valve (see Figure IA). which consist of
PY-CEI/NRR-1389 L i
Page 5 of 11 only one TRIP SYSTEH. Thus, having two separate ranuirements based on the number of affected TRIP SYSTEMS for ti-se instroments is not correct. The wording of ACTION 34 has been revised to require placing any inoperable channels in the tripped condition
'lithin I hour or declaring the llPCS system inoperable.
This gives the operator the ability to place inoperable channels in the tripped condition if doing so vould not cause a llPCS in.itiation, or of declaring the llPCS system inoperable if placing the channels in trip would cause an actuation.
If the channels are placed in the tripped condition, a valid LOCA signal vould cause the llPCS system to actuate as designed. This change also makes this ACTION consistent with the revised actions for these same instruments in Tabic 3.2-1 discussed above.
In both Specifications, if the operator can place the inoperable channels in the tripped condition the Actions permit this action.
If placing the inoperable channels in the tripped condition vould cause the 1E22-F023 valve to isolate and would cause a liFCS actuction, the Specifications require that the llPCS system be declared inoperab's and that the IE22-F023 valve be isolated.
The second change to this Table involves the required ACTION for the Reactor Vessel Vater Level - liigh Level 8 Trip Function for the Division 3 Trip System. These Level 8 instruments isolate the llPCS Injection Valve (1E22-F004) when the Reactor Vessel Vater Level reaches Level 8.
Like the Level 2 and Dryvell Pressure instruments asso.inted with the itPCS system, these instruments are combined in a one-out-of-two-taken-twice logic (see Figure 4).
The required action (ACTION 31) to declare the !!PCS system inoperable is not consistent with this logic, or with the actions required when the llPCS Level 2 or Dryvell Pressure channels become inoperable. Therefore, the required ACTION has been changed to be
'he newly revised ACTION 34, which requires the inoperable channels be pieced in the tripped condition or that the llPCS system be declared inopernble.
In this vsy, if placing the inoperable enannels in trip does not cause the TRIP FUNCTION to occur, the llPCS system does not have to be declared inoperable.
At the same time, the act of placing any of the inoperable channels in the tripped condition vill permit a valid Level 8 trip signal to isolate the discharge valve.
If placing a chanael into the tripped condition vill cause the TRIP FUNCTION to occur however, the channel vill not have to he placed in trip, 'out instead the llPCS system vill be declared inoperable, resulting in a limited time duration on the Instrument inoperability.
I 1
l-PY-CEI/NRR-13fl9 L L
Page 6 of 11 SIGNIFICANT llAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Comn:ission's Regulations, 10CFR50.97, which state that the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previoasly evaluated, (2) create the possibility of a new or dif f erent kind of accident from any previously evaluated, or (3) involve a significant reduction in a margin of safety.
The proposed amendment has been reviewed with scapect to_these three factors and it has been determined that the proposed changes do not involve a significant hazard because:
1.
These changes do not involve a significant incicase in the probability or consequences of an accident previously evaluated.
None of the proposed changes involve any design changes to the plant, nor do they invelve chanFes that could affeet any previous accident analyses.
The major changes to Table 3.3.2--I simply involve a bet ter identification of the Division 3 instrumentation used to isolate one contait. ment isolation valve, IE22-Fu23. The change vill result in more conservative and appropriate actions for an inoperability of one or more of these Division 3 instruments than is presently requited by the specifications.
The new Action vill ensure that the isolation function remains capable of completing its function, or that the isolation valve is closed. Thus, the probability or consequences of any previously evaluated accident vould remain the same or decrease as a result of this part of the change. The rest of the changes to Table 3.3.2-1 are editorial, and therefore have no bearing on the probability or consequences of r.n accident.
The changes to Table 3.3.3-1 also will not increase the probability or-consequences of any previously evaluated accident. The change being made to Action 34 is being made to correct an error which has previously existed in the Action statement, namely it inferred that two TRIP SYSTEHs exist for the Reactor Vessel Vater Level - Lov Level 2, and-the Dryvell
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Pressure - Illgh TRIP FUNCTIONS. The revised Action statement vill reflect
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the d ngle trip system that exists, and vill always require that the TRIP FUNCTION remain capable of performing its function or that the ilPCS system be declared inoperabic. The length of time permitted for the llPCS system to be-inoperable has not changed as a result of this request. The other change to Table 3.3.3-1 involves changing which ACTION applies to the l
Reactor Vessel Vater Level - liigh Level b TRIP FUNCTION. The revised l_
ACTIOM again always assures that the TRIP FUNCTION remalrs operable, or requires that the' llPCS system be d.clared inoperable.
As previously stated this does not affeet any previous accident analyses.
l-I l
PY-CEI/NRR-1389 L Page 7 of 11 2.
The proposed changes do not create the possibility of a new or different kind of accident from any previous evaluated. None of the proposed changes involve any actual design changes to the plant, nor any changes to plant procedures, operation of the associated systems or reliability _of the instruments.
As stated above, these change requests are tither clarifying the presently existing instrumentation for containment Isolation valves and HPCS Actuation instrumentation, or are editorial changes. Therefore, there is no new or different type of accident being created as a result of these changes.
3.
The proposed changes do not involve a significant reduction in the margin of safety.
The revised ACTION statements vill always maintain the TRIP FUNCTIONS of the instrument channels involved or vill require that thp HPCS system be declared inoperable.
In addition, the revised ACTION for the Division 3 isolation instrumentation channels vill require that if_the isolation instrumentation furation cannot be maintained, the.t the lE22-F023 valve be r
shut and deenergized thus providing the intended safety function of the l
inoperable instruments. The remaining changes are editarial changes to make the Technical Specifications consistent. Thus the margin of safety vill not be affected by these proposed changes.
Environmental Consideration The proposed Technical Specification change request has been reviewed against the criteria of 10 CFR 51.22 for environmental considerations.
As shown above, _the proposed change does not involve a significant hazards consideration, nor increase the types and amounts of ef fluents that may be released offsite, nor significantly. increase individual or cumulative occupational radiation exposures.
Based on the foregoing, it has been concluded that the proposed Technical Specification change meets the criteria given in 10 CFR 31.22(c)(9) for a categorical exclusion from the requirement for an. Environmental Impact Statement.
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