ML19332F794

Responds to NRC 890531 Request for Addl Info Re NRC Bulletin 88-004, Safety-Related Pump Loss. Info Covers pump-to-pump Interaction That Could Result in Deadheading & Adequacy of Min Flow Bypass Lines Against Pump Damage

ML19332F794
Person / Time
Site:	Perry
Issue date:	12/13/1989
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-88-004, IEB-88-4, PY-CEI-NRR-1081, TAC-69954, NUDOCS 8912190044
Download: ML19332F794 (5)

Text

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THE CLEVELAND ELECTRIC-lLLUMINATING COMPANY il ~

P.O. BOX 97 9 PERRY. OdlO 44061 5 TELEPHONE (216) 2694 737 5 ADDRESS 10 CENTER ROAD

l. FROM CLEVELAND: 241 1660 l Serving The Best location in the Nation Al Kaplan PERRY NUCLEAR POWER PLANT

/; WCE PRCDDENT December 13, 1989 l PY-CEI/NRR-1081 L II.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Request for Additional Information NRC Bulletin 88-04, Safety-Related Pump Loss (TAC No. 69954)

Gentlemen:

NRC Bulletin 88-04 requested the evaluation of all safety-related pumps for

-(l) pump-to pump interaction that could result in dead-heading, and'(2) adequacy of minimum flow bypass lines, with-respect to pump damage. The PNPP response by letter PY-CEI/NRR-0879L, dated July 11, 1988, concluded that the potential for pump damage was negligible, and that the. Perry licensing. basis was not affected.

By May 31, 1989 letter from Colburn to Kaplan, the NRC requested additional information (RAI) on RCIC pump minimum flow. Specifically, the NRC requested that Cleveland Electric Illuminating Company (CEI) demonstrate how operators would be able to avoid minimum flow operation or sufficiently limit minimum flow duration to avoid RCIC pump damage during all expected operating occurrences. At the time of that correspondence, the limit had been set by the pump manufacturer at 20 seconds.

'Our response to the May 31 RAI is in two parts, (1) avoidance / limitation on RCIC minimum flow, and (2) impact on the Perry Ahticensing basis.

RCIC Minimum Flow Avoidance / Limitation l

The outboard containment isolation valve on the RCIC pump discharge line L.

(F013) is normally maintained closed to provide positive isolation in standby readiness (nttached figure). Valve F013 will automatically open on a RCIC system initiation signal if both the RCIC turbine steam supply valve (F045) and the turbine trip-throttle valve (F510) are at least off their fully closed seat, indicating they are open or in the opening process. Both F045 and F510

l. must be open in order for the RCIC pump to operate. If either F045 or F510 is l in the fully closed position, F013 will automatically close to prevent l'

backleakage into the RCIC pump discharge piping when the RCIC pump is not in

l. operation.

8912190044 891213 e l'637 PDR ADOCK 00000400 Q . PDC

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"", Decub3r 13,1989

..,, USNRC . a+> PY-CEI/NRR-1081 L The RCIC pump manufacturer.vas contacted to reverify allovable time at rated-speed of 4550 rpm and minimum flow rate of 120 gpm. The manufacturer has determined that the RCIC pump can operate under these conditions for 10 minutes in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period without damages the following guidance on allovable operating times for a range of operating conditions is included in the system operating instructions to implement the manufacturers recommendations:

" Maintain the RCIC Pump flov greater than or equal to the following limitations:

30 minutes 10 minutes RPM Continuous Duty in 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period in 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period 2250 140 GPM 85 GPM NA 2250 345 GPM 225 GPM 120 GPM NOTE: RCIC MIN FLOV VALVE, 1E51-F019, passes 120 GPM" CEI has reviewed the following RCIC system design, control logic, automatic and manual modes of operation

- automatic initiation sequence

- automatic pump trip sequences, including Level 8

- manual startup and valving sequence

- valve lineups / sequence for operating modes other than reactor vessel injection

- manual shutdown

- recovery from isolation and turbine trip Based on this review, we have concluded that the RCIC pump is protected against dendheading/ low flow damage in all automatic modes of operation, and that operating instructions correctly sequence valve operations and contain adequate precautions to provide equivalent protection during manual. modes of operation.

In the automatic mode of operation, the causes of flow through the minimum flow line are (1) pump operation while the outboard containment isolation valve on the RCIC pump discharge line (F013) is still opening (less than 20 seconds), or (2) an F013 failure in the closed position. In the event of F013 failing to automatically open on a RCIC system initiation signal, control room-indications and alarms (attached table) would notify the operators so that attempts could be made to open the valve. System failure from exceeding minimum flow time limitations following automatic start is therefore limited

-to F013 failing to open with no successful operator action taken within 10

. minutes to open F013, or align an alternate flow path to the condensate storage tank, or shut down the RCIC turbine, all of wh'ich are addressed by procedures and training.

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.,- USNRC ,

Decnber 13, 1989 PY-CEI/NRR-1081 L

The RCIC system can also be operated manually for such purposes as surveillance flow testing, decay heat removal with the reactor vessel isolated, and override of an automatic initiation signal. For manual operations the operator is at the RCIC controls, with tabulated alarms and indications to varn of inadvertent F013 closure. The System Operating Instruction precautions described above and valve operating sequences are written to avoid, or to minimize, RCIC pump minimum flow operation. In addition, there are no instructions or training under normal, off-normal or emergency conditions to purposely close F013 unless the RCIC system and pump

are being shut down.

Furthermore, there are no analyzed normal, transient, or-secident plant conditions which rely on the RCIC system to remove decay heat.

Perry Licensing Basis The Perry plant was licensed with the design philosophy that RCIC is a single

train system and therefore subject to single failures, one of which may be F013 closure with the pump running for greater than 10 minutes. This failure does not represent a condition beyond the Perry licensing basis.

Bulletin 88-04 Item 4 requested that particular regard be paid to General Design Criterion 35 of Appendix A to 10CFR 50, and 10CFR 50.46. These references apply to emergency core cooling systems (ECCS), their capability to maintain core cooling under design basis accident conditions, and specifically require redundant ECCS design features. The Perry RCIC system is not classified as an ECCS, does not need to meet ECCS criteria for redundancy, and is not relied upon to meet ECCS performance criteria as analyzed in Perry USAR Chapters 6 and 15.

-These criteria are satisfied, and Perry is-justified to continue operating as originally licensed,:in accordance with the demonstrated performance of other plant systems which in combination are classified ECCS: High Pressure Core Spray, Lov Pressure Core Spray, Lov Pressure Coolant Injection mode of the Residual Heat Removal System, and the Automatic Depressurization System.

Irrespective of RCIC configuration or operator response upon RCIC demand, the Perry licensing basis remains consistent with the bases for justifying continued operation cited in Bulletin 88-04. If you have any further questions, please feel free to call.

Very r ly yours,

' i .

Al Kaplan Vice President Nuclear Group AKinjc Attachment cc: T. Colburn P. Hiland U.S. NRC Region III

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Attachment PY-CEI/NRR-1081 L i

t Control Room Indications and Alarms for RCIC Injection Flov Status Indications RCIC Flov 0-800 gpm Pump Discharge Pressure- 0-1500 psig Valve F013 Position close/open Alarms RCIC Pump Discharge / Flow Lov 120 gpm setpoint RCIC Isolation Initiated

• RCIC MOV Power Loss

• i Logic Power Loss *

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