ML20113E134

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Updates Info in 830114 & 1101 Ltrs Re Inadequate Core Cooling Design Changes.Generic Ltr 84-23 & NUREG-0737,Item II.F.2 Also Addressed.Info Closes Out License Condition 4 of Ser.Addl Details on as-built Configurations of Sys Encl
ML20113E134
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 01/14/1985
From: Edelman M
CLEVELAND ELECTRIC ILLUMINATING CO.
To: Youngblood B
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM GL-84-23, NUDOCS 8501230323
Download: ML20113E134 (3)


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P.o. BOX 5000 - CLEVELAND. OHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLICSoVARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT NUCLE A R January 14, l985 PY-CEI/NRR-0168 L Mr. B. J. Youngblood, Chief Iicensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 License Condition No. 4:

BWROG Inadequate Core Cooling (ICC)

Report Implementation Actions

Dear Mr. Youngblood:

This letter is provided to update information previously submitted by letter dated January 14, 1983 (PY-CEI/NRR-000lL) and November 1, 1983 (PY-CEI/NRR-0080L). Those submittals described the design actions planned for Perry Nuclear Power Plant (PNPP) in response to the recommendations of the BWROG Reports SL1-8211 and SLI-8218. The actions described have since been designed and built into the plant. The attachment to this letter provides additional details on the as-built configurations of the systems.

This letter also addresses Generic Letter 84-23 regarding reactor vessel water level instrumentation. The Generic Letter describes the categories of potential physical improvements which the NRC staff recommends be made to BWR plants in order tc improve the accuracy and reliability of the water level systems and satisiy the requirements of NUREG-0737 Item II.F.2. The recommended plant design changes and equipment noted in the Gene.ric Letter are already incorporated at PNPP, as described in the attachment.

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B. J. Youngblood, Chief January 14, 1985 PY-CEI-NRR-0168L We believe that the information provided will close License Condition 4 in the PNPP Safety Evaluation Report. If there are any questions, please feel free to call.

, Very truly yours, Murray R. Edelm& an Vice President Nuclear Group MRE:nje Attachment cc: Jay Silberg, Esq.

John Stefano (2)

J. Grobe 4

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ATTACHMENT PY-CEI/NRR-0168L This attachment describes the Perry Nuclear Power Plant (PNPE j implementation action in addressing the issue of " Inadequate Core Cooling" detection for BWR plants. Based on an agreement between the Nuclear Regulatory Commission and the BWR Owners Group, the issue of specific requirements for incore thermocouples was broadened to that of monitoring inadequate core cooling. The BWR Owners Group committed to prepare a report analyzing inadequate core cooling instrumentation requirements for subsequent submittal to the NRC staff.

The Perry Nuclear Power Plant as a participant in the BWR Owners Group was directed per Section 4.4.7 of the Perry Safety Evaluation Report (SER)

(NUREG-0887, May 1982) to apply all conclusions / recommendations to its plant design.

In conjunction with the submittal of BWROG Reports SL1-821L and SL1-8218 to the NRC, the PNPP has reviewed and evaluated the reports against its plant design.

Based on this evaluation, the PNPP has concluded that its reactor vessel water level system, as modified by specific changes identified in Report SLI-8211, will provide suitable means for detection of adequacy of core cooling.

Additional new instrumentation to monitor ICC conditions is not considered warranted by Report SLI-8218 provided that the improvements recommended in SL1-8211 are made to the system. SER Supplement 4 (February 1984) noted that the Owners Group and PNPP specific reports were still under staff review; the results of which are presented in Generic Letter 84-23, " Reactor Vessel Water Level Instrumentation in BWR's", dated October 26, 1984.

In accordance with the recommendations of SLI-8211 and Generic Letter 84-23, the following design modifications have been incorporated at Perry Nuclear Power Plant. This information provides the as-built configuration of the modifications.

1) New penetrations have been installed in the drywell walls with water level system reference leg piping rerouted to reflect I foot-6 inches + 6 inches in vertical drop from condensing chambers to the drywell penetrations in all cases but one, where the drop is 2' 3".
2) The new penetrations have resulted in most of the differences in drops between associated reference and variable legs being equal within approximately + 1 foot. In two cases however, the vertical drop is approximately two feet. The largest deviation is less than 2 feet-2 inches, which infers a maximum potential error of only about 3 inches.
3) Reference leg orifices formerly located at the reactor vessel nozzles have been relocated close to and on the inboard side of the drywell penetrations at distances between 2 feet 9 inches and 5 feet 10 inches.

One additional recommendation of SLI-8211 and Generic Lettec 84-23 was to replace mechanical instrumentation used in some BWR plants with analog instrumentation. PNPP uses analog, not mechanical instrumentation in its water level measurement system. Therefore, this recommendation is not applicable to PNPP.

The design actions described above are responsive to the recommendations made in BWROG Reports SLI-82tl and SLI-8218 and in Generic Letter 84-23. The m-difications made to the wide and narrow rar.ge water level system piping configurations assure the system's reliability in the detection of inadequate core cooling conditions. As discussed in Report SL1-8218, the addition of new instrumentation is not warranted due to the modifications made to the Perry Nucicar Power Plant based on Report SLL-82tl recommendations.