PY-CEI-NRR-1425, Application for Amend to License NPF-58,changing TS 3.3.7.4-1 Re Remote Shutdown Sys Controls to Remove Line Item for Controls to RCIC Pump Discharge to Lube Oil Cooler Valve

Application for Amend to License NPF-58,changing TS 3.3.7.4-1 Re Remote Shutdown Sys Controls to Remove Line Item for Controls to RCIC Pump Discharge to Lube Oil Cooler Valve

ML20094L000
Person / Time
Site:	Perry
Issue date:	03/16/1992
From:	Lyster M CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20094L002	List: ML20094L007 PY-CEI-NRR-1425, Application for Amend to License NPF-58,changing TS 3.3.7.4-1 Re Remote Shutdown Sys Controls to Remove Line Item for Controls to RCIC Pump Discharge to Lube Oil Cooler Valve
References
PY-CEI-NRR-1425, NUDOCS 9203240049
Download: ML20094L000 (6)

Text

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t CENTERIOR ENERGY PERRY NUCLEAR POWER PLANT Mait AddTas:

PO. BOX 97 Michael D.1.yster PERRY, OHIO 44081 ,1CE PRESIDENT NUCLEAR l0c g T{ ROAD (216) 259-3737 March 16, 1992 PY-CU/NRR 1425 L ll.S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Ferry Nuclear Power Plant Docket No. 50 440 ,

Technical Specification Change Request: Remote Shutdown Syctem Controls (T.S. 3/4.3.7.4)

Gentlemen:

In accordance with 10CFR50.90, enclosed is a request for amendment of Facility Operating Licensa NPF-58 for the Ferry Nuclear Power Plant (PNPP) Unit 1. In accordance with the requirements of 10CFR50.91(b)(1), a copy of this amendment request has been sent to the State of Ohio as indicated below.

This amendment requer, t proposes a change to PNPP Technical Specification Table 3 3.7.4-1, " Remote Shutdown System Controls", to remove the line item for the controla to the Reactor Core Isolation Cooling (RCIC) pump discharge to lube oil cooler valve. A description of the proposed change, including the Significant flazards Consideration and Er.vironmental Considerati<.ns is included in Attachment 1. A copy of marked up Technical Specification page 3/4 3-75 containing the proposed change is included in Attachment 2.

If you have=eny questions, please feel free to call.

1 Sincerely, - ') ,

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Qf9:A.L&fh

.j,gl Michael D. Lyster /

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PY-CEI/NRR 1/23 L Attachmen*. 1

. Page 1 ci 5

SUMMARY

OF DR3 POSED, CHANGE This Operating License amendment request proposes to remove the line item for the controls to the Reactor Core Isolation Cooling (RCIC) Pump Discharge to hube 011 Cooler Valve from PNPP Uait 1 Technical Specification 3/4.3.7.4, Table 3.3.7.4-1, " Remote Shutdovn System Controls". The referenced valve is currently a normally closed Motor Operated Valve that is . required to autoratically open on RCIC system initiation to provide a source of cooling vater to tLe RCIC pump lube oil coole?. This change 1.5 requested in order to implemene a design change which would convett this valve from a Normally closed Motor Operated Valve to a Locked Open manually operated valve. Tnis  ;

change vould improve system reliability and thereby enhance plan. safety by removing one active component from the RCIC system and roulacing it with a passive valve which would ensure atallability of cooling vater to the Rr!C system lube oil cooler. This design change vill also reduce station battery loads, reduce periodic maintenance costs, and would clicinate costly MOV

-testing and the Equipment Qualification inspection votk required for active components.

I. DESCRIPTION OF CURREb4 LICENSE CONDITION ,

General Design criterion 19 of 10CFR50 Appendix A specifies, in part, that equipment at appropriare Incations outside the Control Room shall be p.:ovidad with a design capability for prompt hot shutdown of tne reactor, including necessary instrumentation and controls to maintain the unit in a safe candition during Hot Shutdown. PNPP Technical Specification 3/4.3.7.4, " Remote Shutdova Sustam lustrumentation and Controls",

L provides Limiting Conditions for Operation (LCO) and Sur~elilance l Requirements to ensure the opetabi41ty of PNPP's remote shutdown system I

as a condition of the PNPP facility operating license. The operability of'PNPP's remote shutdown monitoring instrumentation and controls ensure

( -- that suf ficient capability is available to permit shutdown and

! maintenance of Hot Shutdovn of the unit from locations outside the Control Room. This capability is required in the event Control Room habitability is lost and is consistent with General Design Criterion 19 (reference PNPP Uni t 1 Technical Specification Bases 3/4.3.7.4, page B 3/4 3-5).

! The LCO for PNPP Technicti Specification 3.3.7.4 requires that the Remote

- Shutdown system instrumentation and con trols ?.isted f a Table 3.3.7.4-1 shall be 0..*ableL in Operational Comlitions 1 and 2. - Among the items listed in T ble 3.3.7.4-1 are the controls for the Reactor Core Isolation Cooling (RCIC) pump discharge to lube oil cooler valve (MPL no.

l lE31-F046), which are identified in the' Table as the anCIC Pump Discharr,e L to'L.O. Cooler Valve" controls (reference PNPP Technical Specification ,

page 3/4 3-75). RC1C valve IE51-F046 is currently a Normally Closed Motor Operated Valve that is required to automatically.open on RCIC l

system initiation to prov:Ide a source of cooling vater to the RC.IC pump lube oil cooler (refere:re enclosei RCIC system drawing included in Attachment 1, page 5 af a). The purpose of the RCIC systen is to provide reactor vater inventory make-up follov!ng loss of coolant tlov from the nornal Feedvater System supply source during vessel isolation conditions.

The RCIC system however, is not clnstified as an ELargency Cote Cooling System (ECCS).

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PY-CEIAGR-1425 L I - Attochment 1 1 4 Page 2 of 5 II. - DESCRIPT!9H OF EROPOSED CllANGE This amendment request proposes to remove reference to toe controle for the RCIC system pump discharge tc 1 M oil cooler valve 1E51-F046 from PN?P Unit 1 Technical Specificati T 3/4.3.7.4, Table 3.3.7.4-1. A copy of the marked up fechelcal Specf f. ;ation page reflecting tha requested change is provided in Attachment 2. 3 III. JUSTIFICATION FOR_ PROPOSED CHANGE This change is requested in order to implement a design change which would convert P.CIC valve. lE51-F046 from a Normally Closed (NC) Hotor Operated Valve (MOV) to a Locked Open (LO) manaally opetated valve. The  ;

HOV trill be disabled electncally from the llotor rentrol Center, Control Roem and Remote Shutdovn Panel. The valve vill be locked in the normally  ;

open position and may be closed for maintenance purpose by the actuetor

handsheel only.

Per present design, valve lE51-F046 has to open automatically from its normally closed position on a RCIC system initiation signal to supply ,

cooling vater to the RCIC lube oil cooler . This de: sign is a carry-over from a previous BWR design where tha cooling vnter from the K':IC pump discharge was routed through the lube oil cooler and then on to a barcmetric condenser. The cooling vater was sprayed into the barometric condenser 2.nd was then routed to the Main Condenser througn the-barontric condenen drain. In toe previous SVh design, this valve needed to be clo.nd af ter RClc syste:r. operation to prevent draining vater

'from the Condensate Storage Tank to the Main Condenser. New BVR designs,

.such as those utilized at Petey, do not utilize a Barometric Condenser.

L The lube oil tooler ce+]et is returned to the RCIC pump suction line, making.this a closet loop operation. In this desig,n there is no concern of a vator drainsge problem to the Hain Condenser and therefore, there is no need for this valve to close after RClO system operation. Therefore, L . valve lE51-F046 can Se a manually operates open velve. This design change vas approved by Gen;ral Electric, PHPP's Nuclear Steam Supply System.(NSSS) supplier.

With the new design, the valve vill be locked in the normally open position and cooling vater to the RCIC Jube oil cooler vill always be available wheneter RCIC pump 1E51-C0001 runs. By converting the valve '

.from a_NC HOV to a LO Hanucl:'ealve tha-a vill be no question of whether or not the valve has opened to allow ecoling vater- to the lube oil cooler. There is no need for the velve to close when the RCIC system.is

-not rur.ning because this is a closed loop-design. By leaving the valve  ;

in the normally o9en position the operability of the RCIC syrtem is enhanced as it removes one' active component from the systen and replaces it with a passive valve. RCIC syst em operation from the Control Room and ifrom-the Remote Shutdown Facel as, required by Genera? Design Criteria-19 .

, -(USAR section 3.1.2.2.10) vill not be affected because this vill be a LO Mancal Valve which requires no remote operrstion.

Implementation of this design change vill reduce periodic preventive maintenance costs, and will eliminate costly diagnostic testing and l j

PY-CEI/NRP-1425 L

- Attachment 1 Page 3 of 5 Equipment Qualification inspection vork. Elimination of this Direct Current (DC) DOV vill also reduce station battery loa.i.

IV. SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a requent for amendment imulves no significant hazards considerucions are incluced in the Commission's Regulations, 10CFR50.92, which sts.te that the operation of the faellity in accordance with the proposed amendment vould not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any previously evaluated, cr (3) involva a significant reduction in a reargin of safety.

The proposed amendment has been revieved with respect to these three factors and it has been determined that the proposed change does not L involve a significant hazard because:

I (1) The proposed change does not involre a significat.t inerense in the probability or consequences of an accident previously evaluated.

l.

First, the proposed change does not involve a significant increase l.

in the probability of an occurrence of an accident previously

l. evaluated in PNPP's Updated Safety Analysis Report (USAR). The Reactor Core Isolation Cooling (RCIC) system is a standby system during normal plant operation, and is designed as a system to respond:to help mitigate trsnaients/ accidents that have already occurred. Therefore, changing the RCIC pump discharge to lube o!1  ;

cooler valve from a normally closed rootor-operated valve with L

contrcls in the Remote Shutdovo Roon to a locited open manually l'

I opetated valve vo:ald not cause the probability of an acci. lent previously evaluated in the PMPP-USAR Chapter 15, to increase. And since this valve is not a containment or reactor pressure boundary val"e during normal or.eration the t'esign ehnnge does act subj ect

!- any more piping to reactor pressute and does not increase the 1 probability of a 3 css of coolant accident (LOCA). Consequently, the L proposed change does not increase the probability of any accident preslously evaluated.

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.In eddition, the ptoposed change does not involve a signi+.icant B

increase'in the consecuences of an accident.previously evaluated.

l' The'proporad change does not. affect ths RCIC rystem operation as -

lc d2 scribed in PNPP's USAR section 5.4.6. By changing the valva to a l normally open valve, there is one less active component relied upon l for the RCIC system to perform its design function, resulting in a "

more reliable RCIC system operation. By changing the stCIC pump

! discharge to-lube oil cooler valve to a normally open valve, the list of active components requited for the RCIC syntom to operate is l- reduce.d Ly one. By reducing the number of active components l.

required for the RCIC system to operate, the reliability of the RCIC l system is actually enhanced by the proposed change. By changing the

! vr.lve to a normally open valve, cooling veter to th, RCIC lube oil coolet vill always be available when the RCIC pump runs, and vill no l

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- Attachment 1 i Page 4 of 5 l longer depend on the opening of valve 1E51-P046, thereby further enhancing the reliability of the RCIC systen am well es za'ucing the i 4 probability of a malfunction of equipment important to safety. .

l Consequently, the proposed change dces not invol.e an increase in '

tLe consequences of an accident previously evaluated in PNPP's USAR. j Furthermore, there is no resul* ant increase in post-accident radiological release r?te, duration or radionuclide population an a consequence of msking the valte normally open or a.anually operated. I i Based upon the above, the proposed change c nnot increase the  !

probability or the consequences of any accident previously ,

p evaluated.

(2) The proposed change does not crea'te the pnssibility of a new or l- different Aind of accident from any ace'. dent previously evaluated in PN?P's USAR because the RCIC system function and operability will

. remain unaffected by this proposed changa. Valve IE51-Fi46 3 '.1 b e  !

a normally open valve during RCIC system operation to ensure a

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supply of cooling water to the lube oil cooler. To prevent inadvertent mispositioning, the valve vill be lacked in the open poaition. As a result, no new failure niodes are introduced. -

(3) The proposed charge does not result in a significant rtduction in-the margin of safety, because the proposed change has no effect on '

the functisn of the RCIC system or its ability to perform its safety function. Consequently, the proposed change still provides adequate assurance that the applicable RCIC safety functions are capable of performing their intended function when required. .Therefore, this l

thange does not reduce the margin of safety as defined in the basis l- for any Technical Specification.

L Based upon the above consideration 9, it has been concluded that the proposed change does not involve significant hsrards considerations.

i-.

i ENyIRONMENTAb CONSIDERATION

The proposed Technical Specification change has been revievad against the critaria of 10CFR51.22 for environmen;al consideration 2. At shown above, ,

the proposed change does not involve a significant hazards consideration, L nor does it iacrease the types and enounts of effluents thst may be +

released offsitt, nor does it significantly increase indicioual or cumulative occupational radiation eeposures. Based on the foregoing, it 1 has been concluded that the proposed Technical Spe2'titution change meets

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-the critoria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

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