ML20203H458

Forwards Request for Addl Info Re Proposed License Amend to Revise Allowable Values & Trip Setpoints

ML20203H458
Person / Time
Site:	Perry
Issue date:	02/19/1998
From:	Pickett D NRC (Affiliation Not Assigned)
To:	Myers L CENTERIOR ENERGY
References
TAC-M93399, NUDOCS 9803030236
Download: ML20203H458 (6)

Text

{{#Wiki_filter:_ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ February 19. 1998 Mr. Lew W. Myers /' Vice President - Nuclear, Perry , Centerior Service Company P.O. Box 97, A200 Perry, OH 44081

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT TO REVISE ALLOWABLE VALUES AND TRIP SETPOINTS - PERRY NUCLEAR POWER PLANT, UNIT NO.1 (TAC NO. M93399)

Dear Mr. Myers:

j Your letter dated August 29,1995 (PY CEl/NRR-1969L), proposed revisions to technical specification allowable values and trip setpoints for plant process instruments of selected safety-related instrument channe's. These changes were based on the staff approved GE setpoint methodology in NEDC-31336, " General Electric Instrument Setpoint Methodology," dated October 1986. Subsequent to your initial submittal, concems were identified during conference calls v.nich took place with your staff on May 2,1996, January 28,1998, and January 29,1998. In particular, the proposed technical specification changes indicate that several allowable values have a range which may not be consistent with accepted setpoint calculation methodology Therefore, in order to continue the staffs review, the attached request for additional information has been identified. Please feel free to contact me at (301) 415-1364 if you have any questions. Sincerely, Original signed by: Douglas V. oickett, Senior Project Manager Project Directo Ote 111-3 Division of Reacto- Projects - lilllV Office of Nuclear Reactor Regulation Docket No. 50-440

Attachment:

As stated 1 1 cc: See next page Distribution: -{ @- k I:I PDlli-3 R/F PUBLIC B. Boger G. Grant, Rlli J. Wermiel EGA1 DOCUMENT NAME: G:\ PERRY \PER93399.RAI To receive a copy of this document. Indicate in the box: "C* = Copy without enclosures "E" = Copy with enclosures *N* = No copy 0FFICE PM:PDIII_-3 , ,6 LA:PDIII-3 E BC:HlCB NAME' DPickett " ' EBarnhill Q/r JWermie'* DATE 02/ W 98 02/1S'/98 . 02/12/98

 *See JWermiel to RSavio memo dated 2/19/98 0FFICIAL RECORD (.D /

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Feh utry 19, 1998

 ,I              Mr. Lew W. Myers Vice President - Nuclear, Perry Centerior Service Company P.O. Box 97, A200 Perry, OH 44081

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT TO REVISE ALLOWABLE VALUES AND TRIP SETPOINTS - PERRY NUCLEAR POWER PLANT, UNIT NO.1 (TAC NO. M93399)

Dear Mr,

Myers: - Your letter dated August 29,1995 (PY-CEl/NRR-1969L), proposed revisions to technical specification allowable values and trip setpoints for plant process instruments of selected safety related instrument channels. These changes were based on the staff approved GE setpoint methodology in NEDC-31336, " General Electric Instrument Setpoint Methodology," dated October 1986. Subsequent to your initial submittal, concems were identified during conference calls which took place with your staff on May 2,1996, January 28,1998, and January 29,1998. In particular, the proposed technical specification changes indicate that several allowable values have a l range which may not be consistent with accepted setpoint calculation methodology. Therefore, . in order to continue the staff's review, the attached request for additionalinformation has been identified. Please feel free to contact me at (301) 415-1364 if you have any questions. 3 Sincerely, Original signed by: - Douglas V. Pickett, Senior Project Manager Project Directorate 111-3 Division of Reactor Piojects -lil/IV Office of Nuclear Reactor Regulation Docket No. 50-440

Attachment:

As stated cc: See next page Distribution: PDill-3 R/F PUBLIC B. Boger G. Grant, Rlli J. Wermiel EGA1 DOCUMENT NAME: G:\ PERRY \PER93399.RAI T3 receive a copy of this document, ind 'ete in the box: "C' = Copy without enclosures *E* = Copy with enclosures *N* = No copy 0FFICE PM:PDIII-3 , n G LA:PDIII-3 E BC:HICB l NAME DPickett * " EBarnhill Q/# JWermiel* DATE 02/ \ %'98 02/IE/98 02/12/98

    *See JWermiel to RSavio memo dated 2/19/98 0FFICIAL RECORD COPY

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February 19, 1998 Mr. Lew W. Myers Vice President - Nuclear, Perry Centerior Service Company P.O. Box 97, A200 Perry, OH 44081

SUBJECT:

REC'JEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT TO REVISE ALLOWABLE VALUES AND TRIP SETPOINTS - PERRY NUCLEAR POWER PLANT, g UNIT NO.1 (TAC NO. M93399) b

Dear Mr. Myers:

Your letter dated August 29,1995 (PY-CEl/NRR-1969L), proposed revisions to technical specification allowable values and trip setpoints for plant process instruments of selected i safety-related instrument channels. These changes were based on the staff approved GE setpoint methodology in NEDC-31338,

• General Electric Instrument Setpoint Methodology,'

dated October 1986. Subsequent to your initia' submittal, concoms were identified during conference calls which took place with your staff on May 2,1996, January 28,1998, and January 29,1998. In particular, the proposed technical specification changes indicate that several allowable values have a range which may not be consistent with accepted setpoint calculation methodology. Therefore, in order to continue the staff's review, the attached request for additional information has been identified. Please feel free to contact me at (301) 415-1364 if you have any questions. Sincerely, Qv fM Douglas V. Pickett, Senior Project Manager Project Directorate ill-3 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket No. 50-440

Attachment:

As stated cc: See next page

L. Myers Perry Nuclear Power Plant, Units 1 and 2 Centerior Service Company cc: Jay E. Silberg, Esq. James R. Williams Shaw, Pittman, Potts & Trowbridge Chief of Staff 2300 N Street, NW. Ohio Emergency Management Agency Washington, DC 20037 2855 West Dublin Granville Road Columbus, OH 43235-2206 Mary E. O'Reilly Centerior Energy Corporation Mayor, Village of Perry 300 Madison Aver,me 4203 Harper Street Toledo, OH 43652 Perry, OH 44081 E Resident inspector's Office Roy P. Lessy, Jr. ] U.S. Nuclear Regulatory Commission P.O. Box 331 Akin, Gump, Strauss, Hauer and Feld, L.L.P. Perry, OH 44081-0331 1333 New Hampshire Ave., NW. Suite 400 Regional Administrator, Region til Washington, DC 20036 U.S. Nuclear Regulatory Commission 801 Warrenville Road Radiological Health Program Lisle, IL 60532-4531 Ohio Department of Health P.O. Box 118 Lake County Prosecutor Columbus, OH 43266-0118 Lake County Admir.". ration Bldg. 105 Main Street Ohio Environmental Protection Painesville, OH 44077 Agency DERR-Comsiance Unit Sue Hiatt ATTN: Mr. Zack A. Clayton OCRE Interim Representative P.O. Box 1049 8275 Munson Columbus, OH 43266-0149 Mentor, OH 44060 Chairman Terry J. Lodge, Esq. Perry Township Board of Trustees 618 N. Michigan Street, Suite 105 3750 Center Road, Bcx 65 Toledo, OH 43624 Perry, OH 44081 Ashtabula County Prosecutor State of Ohic 25 West Jefferson Street Public Utilities Commission Jefferson, OH 44047 East Broad Street Columbus, OH 43266-0573 Henry L. Hegrat Regulatory Affairs Manager William R. Kanda, Jr., Plant Manager Cleveland Electric illuminatiry Co. Cleveland Electric illuminating Co. Perry Nuclear Power Plant Peny Nuclear Power Plant P.O. Box 97, A210 P.O. Box 97, SB306 Perry, OH 44081 Perry, OH 44081

cc: (ccatinued) Donna Owens, Director Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009 . Reynoldsburg, OH 43068-9009 Mayor, Village of North Perry ] North Perry Village Hall ] 4778 Lockwood Road North Perry Village, OH 44081 Attomey General Department of Attomey General 30 East Broad Street Columbus, OH 43216

e REQUEST FOR ADDITIONAL INFORMATION During the review of the August 2g,1995, submittal for technical specification (TS) modifications related to allowable values (AVs) and trip setpoints (SPs) for the Perry Nuclear - Power Plant, Unit 1, the staff noted that some of the proposed TS instrument AVs have upper - and lower limits which indicate that these AVs have a range. The staff believes that the appearance of a " range" for any AV as calculated using the NEDC 31336 methodology warrants some clarification. Please provide further information for the following items:

1. For the proposed AVs which give the appearance of a range, please confirm that the upper and lower limits are unique AVs with each AV associated with one unique SP and analytical limit per functional unit in both the increasing snd decreasing directions of the controlled process variable. Also, provide the documentation location for the actunt setpoint chosen and confirm that there is not a setpoint range.

L 2. Please verify that the trip setpoints associated with each proposed upper AV and lower - l AV have been analyzed for potential interactions between the setpoints and that each AV has been located to accurately assess instrument operability during instrument surveillance and satisfy the setpoint calculation uncertainty assumptions.

3. During various conference calls, the staff was informed by the licenw ihat for each functional unit, the actual setpoint has been located anywhere between the two nominal setpoints associated with the upper and the lower AVs. The licensee further stated that the location of the actual setpoint between the two nominal setpoints was done in accordance with the guidance provided by the General Electric Topical Report NEDC-  ;

31336, which was previously approved by the staff. ' Every nominal SP has a calculated allowance between the SP and its AV, which is known as the SP-margin. This is the margin by which the SP is allowed to move between two consecutive surveillances without encroaching on its AV.~ lf the actual SP is located between the two nominal setpoints, then the SP-margin is wider than if the SP was located at its nominal value. Because a SP margin may, therefore, be larger than assumed in the setpoint calculation, an instrument whose characteristics are degraded beyond acceptable limits may be found to be within the calibration allowances in consecutive surveillances without encroaching on its AV. As a result, it may not be possible to accurately assess instrument operability oi that the setpoint calculation assumptions are continuing to be met by the instrument during routine instrument surveillance. In this regard, please discuss the following: a) What steps are taken to ensure that in the presence of a wider SP-margin, assessment of instrument operability is performed accurately during each TS routine surveillance and is it verified that instrument characteristics continue to meet all the assumptions of the plant safety analyses?

                 - b)     Which document will provide adequate clarifications relating to 1) false appearance of AV range,2) wider SP-margin, and 3) information relating to certain steps to meet requirements of item 3.a described above?
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