ML20215J456

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Safety Evaluation Supporting Amend 6 to License NPF-58
ML20215J456
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 06/09/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20215J452 List:
References
NUDOCS 8706250007
Download: ML20215J456 (4)


Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.

6 TO FACILITY OPERATING LICENSE NO. NPF-58 CLEVELAND ELECTRIC ILLUMINATING COMPANY, ET AL.

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By letter dated December 15, 1986, as amended February 10, 1987, Cleveland Electric Illuminating Company, Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company, and Toledo Edison Company (the licensees) requested an amendment to Facility Operating Licens,e, No. NPF-58 for the Perry Nuclear Power Plant, Unit No. 1.

The proposed amendment would make several editorial changes and corrections, and make two administrative changes, the first, to remove organization charts from the Technical Specifications (TSs) and instead incorporate them by reference from the FSAR, and the second, to delete the requirement that NRC approval of items involving'unreviewed safety questions shall be obtained prior to licensee internal approval for implementation.

The proposed amendment would also make several technical changes to the TSs:

using Unit 2 divisional batteries as an alternate DC power source for Unit 1 shutdown, increasing the number and changing the location 7 '

drywell average air temperature instruments, changing the automatic j

depressurization system instrument air low pressure alarm setpoint, deleting an obsolete footnote, and changing the containment vacuum breaker isolation valve opening setpoint.

2.0 EVALUATION The proposed change in Definition 1.18, Fuel Handling Building (FHB)

Integrity regarding the correct reference to specification 3.7.7.1 vice 3.7.9.1 and the proposed change in Table 3.8.4.1-1 are administrative corrections of typographical errors and are, therefore, acceptable.

j The proposed use of Unit 2 divisional batteries as an alternate DC power source for shutting down Unit I was specifically approved in section 16.2.15 of September 1986 Supplement No.10 to the Safety Evaluation Report related to the operation of the Perry Nuclear Power Plant.

The staff, therefore, finds this change to be acceptable.

The licensee has proposed to delete the organization charts that are presently included as Figures 6.'2.1-1 and 6.2.2-1 and references to those figures in TSs 6.2.1 and 6.2.2.

A related change would also revise the wording of TS 6.1.1.

These revisions would simply reference the organization charts and text in Chapter 13 of the Perry FSAR.

The staff 8706250007 870609 PDR ADOCK 05000440 P

PDR

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is considering, as part of the generic Technical Specification Improvement Program, revising the Administrative Controls, including the possibility of deleting the organization charts from Section 6.

The staff has not completed its work in this area.

Therefore, since 10 CFR 50.36(c)(5) requires that the TSs contain provisions relating to the organization of the licensee, the organization charts shall remain in the Perry TSs and the licensee's proposed changes are unacceptable.

The licensee has proposed to delete the requireme it, in TS 6.5.3.1.e.,

that NRC approval of items involving unreviewed safety questions shall be obtained prior to approval by Perry department managers.

The deletion is acceptable because NRC regulations do not include such a requirement; 10 CFR 50.59 requires NRC approval prior to implementation, not prior to approvals by licensee internal organizations.

The licensee has proposed changes to the number and location of drywell temperature instrumentation as contained on TS page 3/4 6-21.

Perry Nuclear Plant TS 3.6.2.6 requires the drywell average air temperature to be below 135 F.

This temperature is used as the initial drywell temper-ature value for design basis loss of coolant accident (LOCA) calculations that demonstrate the peak drywell temperature will not exceed a design peak temperature of 330 F.

Current TS surveillance Section 4.6.2.6 lists six instrument locations, two per elevation at three different elevations.

The requested change would increase the total number of instrument loc-ations from 6 to 17.

The proposed 17 instrt. ment locations are located on three different elevations; four at elt';ation 653'-8", six at elevations from 634'-0" to 640'-0", and seven at elevations from 604'-6" to 609"-8".

The proposed TS (3/4.6.2.6) states that the drywell average air temperature shall be the arithmetical average of the measured temperatures at the above specified three elevations.

At least one reading.from each elevation is to be used for an arithmetical average.

The temperature at each elevation shall be the arithmetical average of the temperatures obtained from all available instruments at that elevation.

These provisions would provide adequate assurance that the final value will represent an average containment temperature without placing undue weight on values from the lower elevations because of the relatively large number of instruments placed there, bioreover, additional instrumentation means a better representation of the drywell.

Therefore, the proposed change is acceptable.

The licensee has proposed to change the surveillance requirement for the opening setpoint of the containment vacuum breaker isolation valve.

Originally the TS read:

"4.6.5.1 Each containment vacuum breaker shall be:

b.

Demonstrated OPERABLE:

3.

By verifying the OPERABILITY of the vacuum breaker isolation valve differential pressure actuation instrumentation with the opening setpoint of greater than or equal to 0.0 psid and less than or equal to 0.112 psid (containment to outside containment) by performance of a...."

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The original proposed modification to the TS was to change the words

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" opening setpoint.

. 0.112 psid" to:

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" opening setpoint of greater than or equal to 0.100 psid with an allowable value of greater than or equal to 0.052 psid" The staff reviewed the proposed modification and was concerned that there

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was no upper limit on the opening setpoint of the valve.

The staff concern was primarily with the fact that the proposed modification could potentially allow the outboard containment isolation valve to be in the open position while there was a high positive containment pressure present.

As a result of the staff concern, the licensee (letter of February 10, 1987) revised the proposed modification to read:

" opening allowable value of greater than or equal to 0.052 psid a:

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less than or equal to 0.160 psid" L

The net effect of this revision is to shift the range of differential l

pressures under which the valve opens upwards about 0.05 psi.

The licensee has stated that this shift is necessary to be in agreement with j

the assumptions used in the accident analysis presented in Chapter 6 of the Perry FSAR.

This shift also maintains the margin necessary for l

ir.strument drift and other system inaccuracies.

The staff agrees with the licensee's rationale for shifting the opening range of pressures to slightly higher values.

The lower value is the i

value used in the accident analysis to calculate offsite doses.

The upper value was selected to account for instrument drift.

Also, the use of the agreed upon modification will not result in the potential for increased offsite releases from all other accidents because the valve 1

closure due to positive pressure will remain unchanged.

The staff therefore concludes that the proposed change is acceptable.

The licensee has proposed to modify the surveillance requirement for the low pressure alarm setpoint for the Automatic Depressurization System (ADS) air supply.

Technical Specification 4.5.1.e.2.c presently requires that l

a channel calibration be performed on the safety-related instrument air system low pressure alarm system and verifying an alarm trip setpoint of

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greater than u. equal ta 155 psig on decreasing pressure.

The licensee has proposed to mo Mfy the acceptance criteria by adding an allowable j

value of greater tha. or equal to 151.9 psig to the surveillance requirement acceptance criteria such that the proposed surveillance requirement would be to verify an alarm trip setpoint of greater than or equal to 155 psig with an allowable value of greater than or equal to 151.9 psig on decreasing pressure.

The licensee provided additional information related to their request by teleconference with the staff on

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May 19, 1987.

The licensee stated that the total instrument inaccuracy for the low pressure alarm setpoint was 1.6 psig.

Further, the licensee stated that line losses in the instrument air lines would be less than

.27 psig.

Thus, an allowable value of greater than or equal to 151.9 psig i

on decreasing pressure using conservative assumptions with respect to

- instrument inaccuracy and line losses still yields an instrument air pressure greater than the 150 psig assumed in the Final Safety Analysis Report for operation of the ADS.

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The licensee also proposed to delete a footnote on the alarm setpoint of the safety-related instrument air system.

The footnote.was required only while the low pressure alarm system was being installed.

Following completion of the installation of-the low pressure alarm system, the footnote.is no longer required and no longer has applicability to the safety-related instrument air system alarm setpoint.

Based on the above, the staff finds the licensee's proposed changes with respect to Technical Specification 4.5.1.e.2.c to be acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change to 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 and/or changes to surveillance requirements.

The staff has determined that the amendment, involves no significant increase.in the amounts, and no significant change in the types of any effluents 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.

Accordingly, this amendment.

meets the eligibility criteria for categorical exclusion set forth in.

10 CFR 51.22(c)(9).

Thi:, amendment also involves changes in recordkeeping, reporting or administrative procedures or requirements. ' Accordingly, with respect to these items, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR SSI.22(c)(10).

Pursuant to 10 CFR S51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance.of this amendment.

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4.0 CONCLUSION

N The staff has concluded, based on the consideratioii~s discussed above,

. s that:

(1) there is reasonable assurance that.the health and safet),of thepublicwillnotbeendangeredbyoperationintheproposeltmanne'r,and (2) such activities will be conducted in compliance with the Coms hsi_on's regulations and the issuance of thi'sT' amendment will not be inbictl' to the common defense and the security non to the health and safety /of the public.

h Principal Contributors:

x T. Colburn L. G. Hulman G. Thomas s

S. Kim R. Benedict

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s Dated:

June 9 1987 W

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