ML20029C364

Application for Amend to License NPF-58,revising Tech Spec 3.3.3 Actions to Make Actions for Various ECCS Actuation Instrumentation Consistent W/Purpose & Logic of Instruments Involved

ML20029C364
Person / Time
Site:	Perry
Issue date:	03/19/1991
From:	Lyster M CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029C365	List: ML20029C364 ML20029C366
References
PY-CEI-NRR-1316, NUDOCS 9103270223
Download: ML20029C364 (11)

Text

_ _ _ - . _

I g cswrs g ay PERRY NUCLEAR POWER PLANT Mail Acess:

P.O. BOX 97 Michael D. LYStef 10 CENTER RCMD PERRY, OHIO 44081 PERRY, OHIO 44081 VICE PRESIDENT NUCLEAR (216) 259-3737 March 19, 1991 PY-CEI/NRR-1316 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 - ECCS Actions Centlement

~

Enclosed is a request for amendment to the Perry Nuclear Power Plant (PNPP)

Unit 1 Facility Operating License NPF-58. In accordance with the requirements of 10CFR50.91(b)(1), a copy of this request for amendment has been sent to the-State of Ohio as indicated below.

This amendment requests revision of Technical Specification 3.3.3 Actions, to make the Actions for various ECCS Actuation Instrumentation consistent with the purpose and logic of the instruments involved.

Attachment 1 providea a Summary.-Safety Analysis, and the Environmental and Significant Hazards consioerations. Attachment 2 provides a-copy of:the proposed Technical Specification changes.

If you have any questions, please feel free to call.-

Since ly, k/0 .

Michael D. Lyct2r MDL:BSF:njc-Attachments

, . cc:- NRC Project Manager NRC Resident Inspector.0ffice NRC Region III State of. Ohio Oteroeg comptr es Cle.e c,4 flectf c Nium+0! rg IOft 2dC f d 900 '

.9103270223 910319 ope 0 v t ? .L332 PDR ADOCK 05000440 1

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• Attachment 1 PY-CEI/NRR-1316 L Page 1 of 9

SUMMARY

This Technical Specification Amendment Request is performing three changes within the-Emergency Core Cooling System (ECCS) Actuation Instrumentation Table (Table 3.3.3-1) of the Perry Technical Specifications.

The first part of this change request concerns changing the vording of ACTION 33 as it relates _to_the Automatic Depressurization System (ADS) instruments.

The ADS actuation' instrumentation presently assigned to this ACTION are the Manual Inhibit Svitches, and the Manual Initiation Switches (Table 3.3.3-1 Items A.2.b, A.2.g, B.2.b and B.2.f). As d aeussed later in this summary, the.

ACTION statement for the Manual Inhibit svitches.is being requested to be changed to ACTION 31, thus the only ADS instruments which vill now be assigned to ACTION 33 are the Manual Initiation Switches.

ACTION 33 presently requires that the " associated ADS valve" be declared inoperable if an instruwnt in one ADS trip system cannot be restored to an OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. . However, for the Manual Initiation switches this action is not meaningful and-vould result in declaring all eight of the ADS valves inoperable even though all eight valves vould still operate

together correctly with any automatic signal from either-the Divkion 1 or Division 2 trip' systems logic,.and all_eight.could still be manually initiated from the other trip systems Manual Initiation svitches, kheproposedchangevouldthereforereviseACTION33tochangethevord

" valve" to " trip; system".- As stated above, the' requirements of ACTION 33 as

presently worded vould require the operator to declare all eight ADS valves inoperable after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.= This vould require the' plant to be placed in HOT-SHUTDOWN vithin the.next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per the requirements of Technical

= Specification 3.5.1 ACTION e.2. =By changing the vording of the ACTION statement from " ADS valve" to " ADS trip system", the required action would be to declare the affected trip system inoperable (which is more appropriate).

Declaring the ADS trip system inoperable vould require ~the operator _to take the: actions stated in Technical Specification- 3.3.3 ACTION c.1 or c.2. These actions permit continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> orEseven days'(depending on the- operability. of high-pressure water injection systems), which' provides a-time period for repair:of the inoperable Manual Initiation function.

The logic and function of the ADS actuation trip systems and Manual Initiation-switches vill be discussed in more detail.in.the Safety Analysis section below.

y Attachment 1 PY-CEI/NRR-1316 L Page 2 of 9 The second part of this change request deals with changing the ACTION statement for the Automatic Depressurization System Manual Inhibit switches (Table 3.3.3-1 items A.2.b and B.2.b.) from ACT *N 33 to 31. The ACTION that is currently assigned to the Manual Inhibit switches, ACTION 33, permits up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore the svitches to an OPERABLE status before requiring that affected ADS equipment be declared inoperable. Action 31 requires that the affected ADS equipment be declared inoperable immediately rather than vaiting 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This change request vould-impose the more restrictive requirement of ACTION 31 for an inoperable Inhibit Switch. The requested change vill bring the action for an inoperable Manual Inhibit switch in line with the required actions when one-of the other ADS instruments in the automatic actuation portion of the ADS logic is found inoperable. The Manual Inhibit switch contacts are in the automatic actuation portion of the ADS logic,.and an inoperable Manual Inhibit switch may prevent one of the ADS trip system logics from automatically actuating the 8 ADS valves. Since the ADS valves vould still actuate from the other ADS trip system, the safety function of the ADS actuation trip logic has been maintained. However, changing the required action to. ACTION 31 eliminates the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> allovable outage period permitted in ACTION 33 prior to declaring the trip syster inoperable. Again this logic vill be discussed in more detail in the safety analysis section below.

The third part of this change request deals with modifying the vording of ACTION 30 to make the vording consistent with that used in the other ACTIONS involving multiple ECCS systems including ADS Actuation instrumentation. This is an editorial change, and does not change the required action in any way.

SAFETY ANALYSIS As discussed above there are three changes to the ECCS-Actuation

-Instrumentation Technical-Specification Tables and Actions. The "itst part of the change request deals with changing the portion of ACTION 33 which deals with ACS channels. Presently four Technical Specification Table. ADS items have' ACTION 33 as the applicable action for inoperable instruments.- The required-ACfION for two of-these Table. items (A.2.b and E.2.b).-is being changed by'the second part of this request.- Thus, only the Manual Initiation channels (Table items A.2.g and_ B.2.f)_ for _ the Division l'and 2 ADS Trip

. Systems vill have ACTION 33 as the required ACTION following approval of this char.ge : equest.  :'

The ADS actuation system is discussed in the USAR Section 7.3.1.1.1.2 and the 1,7.3.3, simplified Sheet 6 of-7.

logic for one trip system (Division 1) is depicted on USAR Figure Figure 1 of this letter is a reproduction of the applicable parts of-the USAR Figure. In addition, Figure 2 provides another.

depiction of the-Division 1 and 2 ADS Trip System logics, and shows that either logic train actuation vill result in all eight ADS valves opening. As ~

shown on this-logic the Manual Initiation pushbuttons form a part of the

-overall--initiation logic for both Division 1 and Divisio'n 2. For Division 1 _ _

[and 2] the ADS logic is initiated manually when the manual initiation pushbuttons in channels A and E [B and F) are depressed and there is a lov pressure ECCS system running (LPCS or LPCI A for ADS Division 1, LPCI B or C

=4 l

l Attachment 1 PY-CEI/NRR-1316 L Page 3 of 9 for ADS Division 2). If both channels in a Division are activated and a pump is running, all eight of the ADS valves vill receive a signal to open. If one or both Manual Initiation channels in either Division become inoperable, the Automatic Initiation portions of the logic vill not be affected in either Division, but the manual initiation function of that particular Division vill be affected. Since the ADS valves themselves are not " divisional," manual initiation of all eight ADS valves could still be accomplished using the manual initiation pushbuttons for the other Division. In addition, each Safety Relief Valve (SRV) has an individual control switch which an Operator could se to open one or more of the SRVs (including any or all ADS valves).

As Action 33 is presently written, if an ADS Manual Initiation channel became inoperable, the channel must be restored in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or the " associated ADS valve" must be declared inoperable. This action is not appropriate for the Manual Initiation channels, and the ACTION statement is being modified to change the vord " valve" to " trip system." As discussed above, Manual Initiation is part of the divisional logic, and when actuated completes logic to open all eight ADS valves. Therefore presently if a Manual Initiation channel becomes inoperable in one ADS trip system, all eight ADS valves vould have to be considered as " associated ADS valves (s)" and be declared inoperable. Technical Specification 3.5.1 ACTION e.2 vould then require the plant to-be placed in HOT SHUTDOVN in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ("vith two or more ADS valves inoperable, be in at least HOT SHUTDOVN vithin 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />...."). This is inconsistent with the actions required for other more important, channels of the ADS trip system, such as the automatic actuation channels.

For' example, as can be seen on Figure 1 and 2 of this letter, the Reactor Vessel Water Level-Lov, Level 3 instruments are vital to the automatic actuation of the ADS trip system. Hovever, the action required when one of these channels becomes inoperable is to declare the ADS trip system inoperable (ACTION 31). This is the appropriate action since the other Division can complete the automatic ADS logic if necessary. If the trip system is declared inoperable, ACTION c.1 of Technical Specification 3.3.3 permits 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or seven days (depending on the operability of the HPCS and RCIC systems) to restore the trip system to OPERABLE status.

Changing the wording of ACTION 33 f rom " valve" to " trip system" vill make the action for the Manual Initiction channels consistent with the other channels of the ADS trip system, and consistent with the logic and purpose of the instruments involved. It vill also contribute to avoiding unnecessary plant shutdowns for an inoperable Manual Initiation channel, while still maintaining the capability to complete the safety function with either Division of the automatic logic.

initiation logic or the other Division of the Manual Initiation The second change being requested by this submittal is changing which ACTION is required for inoperable ADS Hanual Inhibit channels (Technical Specification Table 3.3.3-1 item A.2.b and B.2.b). Even though the name of the function contains the word "Hanual", these channels are in the Automatic portion of the ADS logic as shown in Figure 1 and 2 of this letter.

Therefore, throughout the remainder of this discussion, the function vill be simply referred to as " ADS Inhibit" in order to avoid confusion.

l

l .

e Attachment 1 PY-CEI/NRR-1316 L Page 4 of 9 If an ADS Inhibit channel is inoperable the Automatic actuation of one ADS trip system (Division 1 or Division 2) would be affected. Depending on the failure mechanism, either Automatic Initiation for the affected trip system would be prevented by the inoperable ADS Inhibit channel, or the Operators could be unable to inhibit actuation of ADS (the purpose of the svitch).

Presently-the required action to be taken for an inoperable ADS Inhibit channel is ACTION 33. As discussed in the first portion of this change request, this action presently provides an eight hour allovable out-of-service time before_ action must be taken to declare associated ADS equipment inoperable, and currently the equipment that must be declared inoperable is the " associated ADS valve" (same current ACTION as described above for the Manual Initiation channels). This is not consistent with the actions' required for the other channels in the Automatic portion of the ADS actuation logic.

Therefore, this change request modifies the required action from ACTION 33 to ACTION 31. '

ACTION 31. requires -that _ the associated ADS trip system be declared inoperable if the ADS Inhibit channel becomes inoperable.- This Action is-similar to the proposed revision to ACTION 33 except that-the operator vill not have_the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to ' restore the channel to an OPERABLE status prior to declaring the ADS trip system inoparable. In the same fashion as the Manual Initiation logic described above, an inoperability of an ADS Inhibit function vould currently resultLin a declaration of all eight ADS valves inoperable due to the current ACTION ~33 vording. Again, similar to-the Manual Initiation function, declaring all eight valves. inoperable is not appropriate. . Instead, the trip system should= be declared inoperable, since the ADS valves -can still be actuated by the other trip ~ system's automatic initiation logic, and they-can also be actuated by both Divisions of Manual Initiation. -At first glance,-

therefore, it.vould'seem appropriate to leave the ADS' Inhibit function

-associated _vith ACTION 33, but merely change the word " valve" to " trip system"

-ac proposed in the first part of this-letter._ However, since the ADS Inhibit channel- can af fect :the automatic actuation of -the affected ADS trip system, taking 8. hours prior =to declaring the trip systam inoperable is not appropriate, and notjconsistent-vith the other channels which form the -

automatic portion of the ADS actuation logic.

This. change-is conservative in that it shortens'the time frame provided by the Action before the' trip system must be' declared inoperable, and it still

.provides an opportunity;to' restore the ADS Inhibit function to operable status before forcing a plant shutdown, due to the seven-day time frame provided _vhen

-only~one. Division is inoperable-(and therefore the other Division can complete the automatic initiation-function). Also, inoperabilities of an ADS Manual Inhibit channelido not affect the operation of the Manual Initiation function Lof either Division in any'vay.

l Attachment 1 PY-CEI/NRR-1316 L Page 5 of 9 The final change deals with modifying the vords in ACTION 30 to make them consistent with the vordirg of ACTION 31 and 33. All three of these ACTIONS apply to instruments used in multiple ECCS systems including ADS. ACTION 31' clearly states that the requirements apply *) the " associated ADS trip system or ECCS." As discussed above, ACTION 33 is being revised to also state the

" associated ADS trip system or ECCS". Therefore, for consistency, the ACTION 30 wording is being modified to state this same requirement. The present wording of both ACTION 30 a. and b. directs the operator to declare the

" associated system" inoperable. Since this ACTION is associated vith various ECCS Actuation instruments on Technical Specification Table 3.3.3-1, the ACTION has always been implemented by declaring the associated ECCS system inoperable (for non-ADS instruments associated with ACTION 30) and by declaring the associated ADS trip svstem inoperable for ADS instruments associated with ACTION 30 (Reactor Ves::e1 Level-Level 1). Thus the change to ACTION 30 is an editorial change, merely providing clarification and consistency between ACTIONS 30, 31 and 33.

SIGNIFICANT BAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Commission's Regulations, 10CFR50.92, which state that the operation of the facility 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, or (3) involve a significant reduction in a margin of safety. CEI has reviewed the proposed amendment with respect to these three factors and has determir4ed that the proposed changes do not involve a significant hazard because:

This change does not involve a significant increase in the probability of consequences of an accident previously evaluated.

All three of the proposed changes either eteate a more conservative and/or more appropriate ACTION to be taken in the event one or more of the instrument channels involved become inoperable. The Technical Specifications have alwaya permitted these instrument channels to be inoperable for periods of time provided the remedial steps are taken as required by the ACTION statements.

In the first proposed change the existing required ACTION vas not appropriate for ir. operable ADS Manual Initiation channels, since all ADS valves are uniftrmly affected, and declaring all the ADS valves inoperable after eight

-hours is not consistent with the required actions for channels in the more imr.ortant automatic ADS logic. The existing ACTION forces an nlmost irmediate, unnecessary plant shutdown, with all the attendant cycling of plant r/ stems, despite the fact that the manual initiation functicn is capable of being completed by the other Divisions logic, and the automatic initiation logic, for which credit is taken in the safety analyses, is completely unaffected. The proposed change instead requires that the associated ADS Trip System be declared inoperable, vnich is consistent with the other ADS instrument channels, and it places a time limit on hov long this condition ran exist.

.' l .

Attachment 1 PY-CEI/NRR-1316 L Page 6 of 9 The second proposed change not only makes the required action for the ADS l Inhibit function consistent vith the other instrument channels in the automatic initiation portion of the ADS logic, but requires that the action be l taken immediately when the ADS Inhibit channel is found inoperable, further limiting the time permitted for the channel to be inoperable as compared to the manual initiation logic. Again, the other Divisions logic can complete the automatic safety function during this period of inoperability, and the manual initiation logic is completely unaffected. The Technical Specifications are approved by the NRC to permit inoperable equipment to exist i for limited amounts of time, so that licensees can have some time frame to restore the equipmer'. to an operable status, and not put the plant through unnecessary plant shutdown cycles for inoperable equipment that can norma.11y be ro h n' Z snin a short time. These proposed changes do not create any new or different approach to dealing with these instrument channels. As described above, both changes are to make the required ACTIONS more conservative and/or l

-consistent with other instrument channels within the ADS system logic, and make them consistent with the purpose and logic of the instruments involved.

As such the proposed change does not increase the probability or consequences of any previously evaluated accident.

The final change to the wording of ACTION 30 is merely a clarification of the -

existing requirements, to make the wording of ACTION 30 consistent with ACTION 31 and 33. Since this is merely an editorial clarification of existing requirements, the revision involves no change or increase in the probability or consequences of an accident previously evaluated.

This proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

As discussed above no new or different types of AC' DONS are being proposed by this change request. This change request is attempting to remove some inconsistencies in the requird ACTIONS for inoperable ECCS Actuation Instrumentation. No changes are proposed to the design or operation of any plant systems or components. The proposed change has not created the possibility of a new or different type of accident from those previously evaluated in the llSAR. Therefore, no nov type of accident has been created by this change request.

The safety.

proposed changes do not involve a significant reduction in the margin of The proposed changes do not reduce the margin of safety as defined in the bases for the Technical Specifications. These changes do not modify any of the instrument setpoints or functions. All ECCS systems vill still be capable of performing their intended safety functions. These proposed changes vill either maintain the present margin of aafety or increase it, by reducing the need for annecessary plant shutdowns, while still maintaining the capability to complete the safety function. Therefore the proposed changes do not involve a significant reductjon in the margin of safety.

r  ;

Attachment 1 PY-CEI/NRR-1316 1, Page 7 of 9 ENVIRONNENTAL CONSIDERATION

• - The Cleveland Electric Illuminating Company has reviewed the propose 6 Technical Specification change request against the criteria of 10 CFR 51.22 u for environmental considerations. As shown above, the proposed change'does  !

not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, por significantly increase individual or cumulative occu :tional radiation exptm res. Based on the

- foregoing, CEl concludes-that 'ie proposed Technical Specification change meets- the: criteria-given in IL ;FR 51.22(c)(9) for a categorical exclusion from the requirement for an Eni'ronmentaa Impact Statement. "

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