ML20011D919

Application for Amend to License NPF-58,revising Tech Specs to Implement Generic Ltr 88-16, Removal of Cycle-Specific Parameter Limits from Tech Specs. Parameter Limits Will Be Moved to Core Operating Limits Rept

ML20011D919
Person / Time
Site:	Perry
Issue date:	12/19/1989
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20011D920	List: ML20011D919 ML20011D921
References
GL-88-16, PY-CEI-NRR-1104, NUDOCS 9001030027
Download: ML20011D919 (13)

Text

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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY P.O. BOX 97 3 PERRY, OHl0 44081 5 TELEPHONE (21s) 2643737 5 ADDRESS 10 CENTER ROAD FROM tlLrVELAND: 479 12s0 3 TrLEX: 241699 ANSWERaAC80 CEI PRYO Al Kaptan Serving The Best location in the Nation PEARY NUCLEAR POWER PLANT VCE F9FVJENT NUCLE AR G400P December 19, 1989 PY-CEI/NRR-Il04 L U.S. Nuclear Regulatory Commission.

Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Technical Specification Change Request - Removal of Cycle-Specific Parameters in Accordance with Generic Letter 88-16 From the Technical Specifications Gentlemen The Cleveland Electric 111uminating Company (CEI) hereby requests Amendment of Facility Operating License NPF-58 for the Perry Nuclear Power Plant (PNPP),

Unit 1. In accordance with requirements cf 10 CFR 50.91(b)(1), a copy of this request for amendment has bee.. sent to the State of Ohio as indicated below.

This amendment requesta revision of Technical Specifications 1.8, 3.2.1, 3.2.2, 3.2.3, 5.3.1 and 6.9.1.9. These specifications require changes to the Definitions, Power Distribution Limits, Design Features (fuel assembly description) and routine Reporting Requirements (add Core Operating Limits Report). These changes are being made to implement Generic Letter 88-16

" Removal of Cycle-Specific Parameters Limits from Technical Specifications."

Additionally the associated Bases are being revised for consistency with the Generic Letter. The Bases are included for your information, although not a formal part,of the Technical Specifications (as described in 10 CFR 50.36).

CEI is requesting issuance of this submittal to remove cycle-specific reload requirements by March 15, 1990. Implementation of this request wil1~ allow CEI to estimate end-of-cycle nuclear parameters at a later date in the cycle allowing an increase in accuracy of our predictions for the following c;cle.

Additionally, this will provide a resource savings for the NRC, as no in-depth review of a third-cycle reload license amendment will be required.

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9001030027 891219 PDR P ADOCK 05000440 PDC i

USNRC PY-CEI/NRR-1104 L Page 2 of 2 Attachment 1 provides the Summary, Description of Changes, No lignificant Hazards and Environmental Impact Considerations. Attachment 2 provides a summary listing of the proposed Technical Specification and Bases changes.

Attachment 3 is a copy of the marked up Technical Specifiestions pages.

Attachment 4 is a copy of the marked up Bases pages. Attachment 5 provides an example of how the cycle-specific information formerly within the Technical Specifications would be formatted when it is relocated to the Core Operating Limits Report.

If there are any questions, please feel free to call.

Very truly yo e, Al Kaplan Vice President Nuclear Croup AKinjc Attachments cca P. Hiland T. Colburn NRC Region III J. Harris (State of Ohio) l-

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ATTACHMENT I

SUMMARY

, DESCRIPTION OF CHANGES, SIGNIFICANT HAZARDS AND ENVIRONMENTAL IMPACT CONSIDERATIONS i

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Attach 2:nt 1 PY-CEI/NLR-1104 L Page 1 of 8

SUMMARY

The cycle specific variables in the PNPP Unit 1 Technical Specifications (TS) are evaluated for every reload cycle and updated as necessary. In Generic Letter 88-16 the NRC Staff provided guidance for the removal of certain' cycle dependent core operating limits from the Technical Specifications. ,

The major Technical Specification changes required to implement the Generic l Letter are as follows:

1. Add the definition of the Core Operating Limits Report (COLR) to the definition section in the Technical Specifications. (1.8-Core Operating Limits Report)

2. Transfer the fuel and/or lattice dependent Maximum Average Planar Linear Heat Generation Rates (MAPLHGR) limit curves.to the Core Operating Limits Report. (3.2.1-Average Planar Linear Heat Generation Rate) ,

3. Transfer the cycle / analysis methodology dependent Maximum Average Planar Linear Heat Generation Rate Power and Flov Factor parametric curves (MAPFACp and MAPFAC,) to the Core Operating Limits Report.

(3.2.1-Average Plan &r Linear Heat Generation Rate)

4. Transfer the cycle / analysis methodology dependent Minimum Critical Power Ratio (MCPR) Power and Flow Factor parametric curves (MCPRp and MCPR g ) to the Core Operating Limits Report. (3.2.2 - Minimum Critical Power RRtio)

5. Transfer the fuel and/or lattice specific values of the Linear Heat Generation Rate (LHGR) from the LHGR specification to the Core Operating Limits Report. (3.2.3 - Linear Heat Generation Rate)

6. Revise the fuel design description to be more generic. (5.3.1 - Fuel Assemblies)

7. Add the reporting requirements associated with the Core Operating Limits Report to a new subsection under Specification 6.9 - Reporting Requirements of the Technical Specifications. (6.9.1.9 - Core Operating Limits Report)

Additionally, the Bases of the Technical Specifications are being generalized and revised to reflect application of Generic Letter 88-16.

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d Attach 2:nt.1 PY-CEI/NRR-1104 L Page 2 of 8 ,

DESCRIPTION OF CRANGES y This proposed amendment revises the necessary specifications to remove from the TS the cycle specific information, such as the numerical values (or representation by curves) of certain core and fuel bundle / lattice type dependent power distribution limits. In place of listing the actual numerical  !

value or showing a curve in the TS, each specification references the Core Operating Limits Report (COLR) which is contained in a section of the Plant Data Book (PDB) and provides these values. Together, the Core Operating .

Limits Report Section of the Plant Data Book and the current cycle reload '

safety analyses results (as presented in the General Electric Supplemental Reload Licensing Submittal) describe the fuel and core analysis for any given j cycle.

1 The cycle specific information from the applicable Technical Specifications are assigned to separate entries within the Plant Data Book. This book is available in the Control Room to the Operators and is routinely referred to in l the course of their duties.

l The Plant Data Book provides a controlled method of maintaining useful

! operating information, e.g., shutdown margin curve, current power-flow map, pump curves, generator hydrogen tables, sump flows and capacities etc. The Plant Data Book is controlled under an administrative proceduce; PAP-0505,

" Preparation, Review, Approval, Revision and Cancellation of Plant Data Book Entries," and is included within the PNPP Operations Manual. This procedure provides for 10 CFR 50.59 evaluation of all entries.

The following paragraphs provide a discussion of the parameters included in the Core Operating Limits Report Section of the Plant Data Book and some examples of why these parameters are cycle specific. Guidance for what types of information could be relocated to the Core Operating Limits Report is taken from letters between General Electric and the NRC, summarizing their

! discussions on the subject (References 4 and 5).

l A. Operating Limit MCPR The Technical Specification MCPR Operating Limit is determined by adding l the delta CPR from the most limiting cycle specific anticipated l l

operational occurrence (A00) (or transient) analysis to the Safety Limit l MCPR. The cycle specific A00 analysis delta CPR results are dependent on l the fuel designs loaded, methodology used, and loading patterns. l established for each reload. Based on these considerations, this limit j should be removed from TS in accordance with the guidance of the Generic l Letter and placed in the COLR.

B. MAPLHGR The Maximum Average Planar Linear Heat Generation Rate (MAPLHGR) power distribution limit curves are provided for each fuel / lattice type in the core. New limit values must be added to TS as new fuel designs are loaded. These TS values are determined by considering both thermal-mechanical and emergency core cooling system evaluations. Also, LOCA reanalysis with an improved methodology (e.g., changing from SAFE /REFLOOD to SAFER /GESTR) can result in changes to these values and require a TS update. 'te eliminate an unnecessary license amendment request to update

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PY-CEI/NRR-1104 L Page 3 of 8 MAPLHGR limits (usually each cycle) when new fuel designs are installed in the core or when a reanalysis is performed (since these fuel designs receive prior NRC approval as do the analysis methods), the TS MAPLHGR curves should be relocated to the COLR. ,

C. Power and Flow Dependent MAPLHGR Parametric Curves Plants implement power and flov dependent MAPLHGR limits to assure adherence to the fuel thermal-mechanical design basis during plant operation at off-rated power and flow conditions. These limits are established by performing various anticipated operational occurrence (A00) analyses at less than rated power and/or flow conditions such that the peak MAPLHGR during these events does not increase above the design t basis value. As new fuel designs are introduced, the applicability of the power and flow dependent MAPLHGR limits are either confirmed or modifications are made to these figures. Improved analysis methodology j could also impact.the required TS limits. The single loop multiplier (clamp) value for these curves could change from cycle to cycle as new fuel designs are introduced. For these reasons the power and flov ,

dependent MAPLHGR limits should be relocated to the COLR.

D. Power and Flow Dependent MCPR Limits l Power and flow dependent MCPR limits may be required to prevent fuel design and safety criteria from being exceeded in the event of anticipated operational occurrences (A00) during plant operation at less than rated flow and/or power conditions. These limits are determined by performing various transient analyses at off-rated power and flov l conditions. The applicability of these MCPR Operating Limits for specific fuel designs are confirmed as new-fuel designs are introduced, or modifications to the TS power and flow dependent MCPR limits are made.

t In addition, these limits can be sensitive to the analysis methodology l used during the evaluations of A00s. An example is.the lov flov adjustment required to the MCPRg curves when using the GEXL-Plus l correlation. A further example:is that the MCPR TS curve could be l modified to present a set of feedvater temperatuEe dependent curves which

vould provide equivalent protection to the MCPR Safety Limit at off-rated i power and temperature conditions (as we did during the first cycle of.

operation). Because of the potential for cycle to cycle variation in these TS limits, it is appropriate to remove them from TS and. relocate these curves to the COLR.

E. LHGR Specification The Linear Heat Generation Rate (LHGR) limits are fuel design dependent.

TS license amendment requests may be required to modify the LHGR power distribution limit as new fuel designs are loaded. Therefore, consistent with the relocation of the MAPLHGR and MCPR power distribution limits, the LHGR limits should also be transferred to the COLR.

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Attechm:nt 1 PY-CEI/NRR-1104 L Page 4 of.8 F. Design Features Typically, somewhat detailed descriptions of fuel assembly designs are included in the Design Features section of TS. The descriptions often include information on number of fuel and vater rods, cladding material, active fuel length and bundle enrichments. These details vill change with~the loading of new, approved fuel designs or different enrichments of the same design. For this reason,.the fuel design discussion should be made more generic but require that these designs be developed and analyzed using NRC-approved codes and methods. Additionally, the design description states that the fuel assembly types are identified in the 4 COLR. This approach is based on the BVR Owners Group Technical Specification Improvement Program suggestions and References 4 and 5, and an amendment reflecting this approach was recently approved for another operating BVR.

NO SIGNIFICANT HAZARDS EVALUATION The standards used to arrive at a determination that a request for amendment requires no significant hazards consideration are included in the Commission's Regulations, 10 CFR 50.92(c), which states 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 previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. CEI has reviewed the proposed changes with respect to l these three factors.

l Removal of Cycle-Specific Parameter Limits from Technical Specifications

1. The proposed amendment does not involve a significant increase.in the probability or consequences of any accident previously evaluated. There vill be no change in the operation of the facility as a result of the amendment. No safety-related equipment or function vi'll be altered. The .

proposed amendment merely removes cycle-specific parameter limits.from l the Technical Specifications and references their. inclusion in the Core Operating Limits Report section of the Plant Data Book. NRC approved analytical ruethodology vill continue to be used as the basis for the limits that will now be contained in the COLR. '

? l The removal of the cycle-specific core operating limits from the PNPP l Technical Sr e ifications has no influence or impact on the probability of l a Design Basis Accident (DBA) occurrence. The cycle-specific core operating limits, although not in Technical Specifications, vill still be J followed in operating the Perry plant. The proposed amendment still l requires exactly the sama actions to be taken if limits are exceeded as l is required by the current Technical Specifications.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. As stated above, no safety-related equipment, safety functions, or plant operations will be altered as a result of this amendment. The requested change does not create any new accident mode. The proposed' amendment is in accordance with the guidance provided in Generic Letter 88-16 for

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-i Attechmnt 1 PY-CEI/NRR-1104 L Page 5 of 8 requesting removal of the values of cycle-specific parameters from Technical Specifications. The establishment of these limits in accordance with an NRC approved methodology and the incorporation of these limits into the Core Operating Limits Report section of the Plant Data Book vill ensure that proper steps have been taken to establish the values of these limits. Furthermore, the submittal of the Core Operating i Limits Report to the Commission vill allow the Staff to continue to trend and review the values of these limits.

As stated earlier, the removal of the cycle-specific variables has no influence on, nor does it contribute in any way, to the probability or consequences of an accident. The cycle-specific variables are calculated using NRC approved methods. The Technical Specifications vill continue-to require operation within the required core operating limits and ,

appropriate actions vill be taken when or if limits are exceeded. r

3. The proposed amendment does not alter the requirement that the plant be operated within the-limits for cycle-specific parameters nor the required remedial actions that must be taken if these limits are act met. While it is recognized that conformance with_such limits is essential to plant safety, the values of such limits can be determined in accordance with NRC approved methods without affecting nuclear safety. The removal of the values of these limits from the PNPP Technical Specifications'is coincident with their incorporation into the Core Operating Limits Report section of the Plant Data Book which together with reload analyses results is submitted to the Commission. Hence, appropriate measures exist to control the values of these limits. Therefore, the. proposed changes are administrative in nature and do-not impact the' operation of-the facility in a manner that involves a reduction in the margin of safety. Indeed, as stated in Generic Letter 88-16, the proposed amendment is responsive to industry and'NRC efforts on improvements in Technical Specifications, and vill result in a resource savings for the licensee and the NRC by eliminating the majority of' license amendment l

requests for changes in values of cycle-specific parameters in Technical l Specifications. Indirectly, this is a safety improvement because the.

released resources may now be utilized on more consequential tasks.

I The margin of safety is-not affected by the removal of cycle-specific core operating limits from the Tehnical Specifications. The margin of safety presently provided by the current Technical Specifications remains-unchanged. The proposed amendment still requires operation within the.

core limits as obtained from NRC approved GE reload design methodologies-l (currently those described within GESTAR-II) and appropriate actions to l be taken when or if limits are violated remain unchanged.

ENVIRONMENTAL CONSIDERATION Clevel'and Electric Illuminating has reviewed the proposed Technical Specification change 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

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effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, CEI concludes that the proposed Technical Specification changes meets the_ criteria set forth in 10 CFR 51.22(c)(9) for a categorical' exclusion from the

! requirement for an Environmental Impact Statement.

Attachr:nt'l PY-CEI/NRR-1104 L Page 6 of 8 p JJ-REFERENCES i

1. USNRC Generic Letter 88-16, " Removal of Cycle-Specific Parameter Limits from Technical Specifications," October 4, 1988.

2. " General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A (latest approved revision) and NEDE-24011-P-A-US (US Supplement - latest approved revision). l

3. Letter from A.C. Thadani (USNRC) to J.S. Charnley (GE), " Acceptance for Referencing of Amendment 19 to General Electric Licensing Topical Report NEDE-24011-P-A (GESTAR-II), ' General Electric Standard Application for Reactor Fuel,' April 7, 1987," November 17, 1987.

4. Letter from J. S. Charnley (GE) to M.V. Hodges (USNRC), " Implementation of Generic Letter 88-16," May 10, 1989. l 1

5. Letter from J.S. Charnley (GE) to M.V. Hodges (USNRC), " Acceptance Implementation of Generic Letter 88-16," August 8, 1989.

6. BVR Owners Group, Improved BVR Technical Specifications, NEDC-31681, April 1989, Volume 5 - BVR/6 Technical Specifications. j l

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ATTACHMENT 2

SUMMARY

OF PROPOSED TECHNICAL SPECIFICATION AND BASES CHANGES i

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PERRY GEIT 1 PROPOSED TECatICAL SPECIFICATION / BASES CHANGES IN ACCORDANCE WITH GRERIC LETTER 88-16 Specification No./ Revised Table / Figure Specification Title Description of Change Page 1.8 (Definition) CORE MAXIMUM FRACTION OF Delete Core Maximum Fraction 1-2 (add to Index) LIMITING POWER DENSITY (old) of Limiting Power Density -

, change to definition not.used in Tech.

CORE OPERATING LIMITS REPORT Specs. since flow biased (new) APRM Scram and Rod Block Specification was deleted when changes were made to ~

implement MEOD. Add in its ,

place the definition for'the Core Operating Limits Report.

3/4 2.1 AVERAGE PLANAR LINEAR HEAT Replace the specific 3/4 2-1 GENERATION RATE references to the MAPFAC figure numbers within the LCO and Action Statements -

with references to the Core Operating Limits Report.

- Delete "*" note since now contained in the Core Operating Limits Report. y3g on ie

! Figure 3.2.1-1 ' FLOV'DEFENDENT MAPLHGR Delete figure transferred Delet'ed *O$

i (delete in Index) FACTOR.(MAPFACg ) to the Core Operating Os Limits Report.  %$

.' %7" Figure 3.2.1-2 POWER DEPENDENT MAPLHGR_ Delete - figure transferred Deleted g{ p j (delete in Index) FACTOR'(MAPFACp ) to the Core Operating  :-

Limits Report. e Figures 3.2.1-3 thru 6 MAPLHGR VERSUS AVERAGE PLANAR Delete - MAPLHGR figures ' Deleted (delete in Index) EXPOSURE FUEL TYPES: transferred.to~the Core BP8 SRB 219 Operating Limits' Report.-

BP8 SRB 176 BS301E_

BS301F y y u- p- m-pp # y'- mn w- p q -sms _ ,', _ _ . , 3_-m__ _ _ _ _ _ _ _ _ __y __,4 ____.gp_ ,

i PERRY WIT 1 PROPOSED TECWICAL SPECIFICATION / BASES CHANGES -IN ACCORDANCE WITH GEIERIC LETTER 88-16 Specification No./  :

Revised Table / Figure Specification Title Description of Change Pat 3/4 2.2 MINIMUM CRITICAL POWER RATIO Replace the specific 3/4 2-2 references to MCPR figure nitabers within' the LCO, Action Statement and Surveillance Requirement sections with  ;

references to the Coro i Operating Limits Report.

Renumber page 3/4 2-7 as page 3/4 2-2.

Figure 3.2.2-1 FLOV DEPENDENT MCPR Delete - figure transferred - Deleted (delete in Index) FACTOR '(MCPRg ) to the Core Operating Limits Report.  ;

Figure 3.2.2-2 POWER DEPENDENT MCPR ' Delete - figure transferred Deleted (delete in Index) FACTOR (MCPR-) p to the Core Operating Limits-Report.

3/4 2.3 LINEAR HEAT GENERATION RATE Replace the references to 3/4 2-3 the specific IRGR values j vith a reference to the - m,>  ;

i Core Operating Limits Report. $ *f "

Renumber page 3/4 2-10-as *2#

- page 3/4 2-3. 3. R l  ;

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5.3.1~ FUEL ASSEMBLIES Generalize fuel assembly 5-4 P., 7 "

description and add' reference Zu to;the COLR. All fuel designs 2 receive prior NRC approval'in e accordance with GESTAR-II.

6.9.1.9 CORE OPERATING LIMITS REPORT Add administrative reporting 6-21 (add to Index) requirement in accordance with' Generic Letter 88-16. ,

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PERRY UNIT 1 PROPOSED TECHNICAL SPECIFICATION / BASES CHANGES IN ACCORDANCE WITH GEIEEtIC LETTER 88-16 Specification No./ .

Revised Table / Figure Specification Title Description of Change Page Bases 3/4 2.1 AVERAGE PLANAR LINEAR HEAT Replaced the specific references B3/4 2-1

GENERATION RATE to the MAPLHGR figure numbers and 2-2 with reference to the Core Operating Limits Report.

Bases 3/4 2.2 MINIMUM CRITICAL POWER RATIO Deleted reference to Cleveland B3/4 2-4 Electric's November 28 and December 29, 1988 subaittal letters. Original issue Tech Specs referenced MEOD and standard power-flow map bounding-input conditions Tables. The subaittal letters are a result not an input. Changed specific-reference to Figure 3.2.2-2 to the MCPR figure contained in the Core OpeFating Limits Report.

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