IR 05000440/1993018
| ML20059G771 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/02/1993 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Stratman R CENTERIOR ENERGY |
| References | |
| NUDOCS 9311090077 | |
| Download: ML20059G771 (2) | |
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November 2, 1993 l
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Docket No. 50-440
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l Centerior Service Company
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i ATTN: Mr. R..
I Vice President
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Nuclear-Perry
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P. O. Box 97, 5270 Perry, OH 44081
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Dear Mr. Stratman:
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This will acknowledge receipt of your letter a4ted October 18, 1993, in
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l response to our letter dated September 17, 1993, which transmitted a request j
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for information associated with Inspection Report No. 50-440/93018. This
report summarized the results of a reactive followup emergency operating
procedures (EOP) inspection at your Perry Nuclear Power Plant. The j
i information requested concerned how existing plant procedures met the. intent i
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of the Boiling Water Reactor Owner Group (BWROG) Emergency Procedure i
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i Guidelines (EPGs) for secondary containment control. We have reviewed your
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response and have no further questions at this time. The actions discussed in I
your response will be examined during future inspections,
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Original signed by Mark A. Ring
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i Mark A. Ring, Chief Operations Branch Division of Reactor Safety i
Enclosure:
Ltr dated October 18, 1993 See Attached Distribution
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R Rill Rg Ig RIII i
Langstaff/cg Nkit b. Burgess L k ury Ring 11/1/93 11///93 11/f/93 11/L/93 11/2 ) 93-
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9311090077 931102
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Centerf service Company
November ~% 1993
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Distribution cc w/o enclosure.
R. M. Schrauder, Director, Nuclear Services Department Kevin P. Donovan, Manager,
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Regulatory Affairs Section N. L. Bonner, Director, Perry Nuclear Engineering Dept.
H. Ray Caldwell, General Superintendent Nuclear Operations David P. Igyarto, Plant Manager R. J. Stransky, Jr., LPM, NRR Resident Inspector, RIII L. A. Arildsen, HHFB, NRR cc w/ enclosure:
Terry J. Lodge, Esq.
State Liaison Officer, State of Ohio Robert E. Owen, Ohio
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Department of Health
A. Grandjean, State of Ohio, Public Utilities Commission bec: PUBLIC - IE01
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9 centenon
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ENERGY
" PERRY NUCLEAR POWER PLANT Mad Address:
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PO. BOX 97 D " ER PERRY, OHIO 44081 VICE PRESIDENT - NUCLEAR E Y Og O 4 081 (216) 259-3737
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October 18, 1993 PY-CEI/NRR-1710 L l
U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Perry Nuclear Power Plant Docket No. 50-440 Response to Request for Information Gentlemen:
This letter provides Perry Nuclear Power Plant (PNPP) response to the request for information in Inspection Report 50-440/93018 dated September 17, 1993 regarding Open Item 440/91013-04. The report documented the results of the
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Emergency Operating Procedures (EOP) Follow-up Inspection led by Mr. R.
j Langstaff on August 22-27, 1993.
Inspection Report 50-440/93007, dated July 23, 1993, requested that PNPP provide a detailed evaluation of how existing plant procedures meet the intent of the Secondary Containment Control (SCC) guidelines. By letter dated August 6, 1993 (PY-CEI/NRR-1684L), PNPP agreed to perform an evaluation of how existing plant procedures meet the intent of the SCC guidelines and submit the evaluation results to the NRC.
Submittal of the evaluation results was delayed from the original proposed date of August 30, 1993 as discussed between Mr. R.
Langstaff (NRC) and Ms. L. Routzahn (PNPP).
NRC Inspection Report 50-440/93018 requested the following information:
(1) a summary of the report developed to determine hov existing instructions meet the intent of the secondary containment control guideline; and (2) any corrections to the conclusions presented in previous submittals concerning secondary containment control. The inspection report also indicated PNPP's agreement to provide a copy of the final evaluation report to the h3C resident inspector's office.
OCT 211933 Operchng Companies Cleve!and Eiedoc mumina ing Toledo Edison 48!Gk2bMS
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-2-PY-CEI/NRR-1710 L October 18, 1993
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Response to the request for information is provided by Attachment 1.
A copy of the secondary containment control evaluation dated August 26, 1993, was provided to the NRC resident inspector's office on September 30, 1993.
If you have any questions or require additivnal information, please contact Kevin Donovan, Manager - Regulatory Af fairs, at (216) 259-3737 extension 5606.
Sincerely,
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f l /)A. StratmanW= '
Ro rt RAS:1EJ1 Attachment cc:
NRC Project Manager NRC Resident Inspector Office NRC Region III i
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PY-CEI/NRR-1710 L
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Attachment 1
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Page 1 of 3 RESPONSE TO REQUEST FOR INFORMATION I.
RESTATEMENT OF THE REQUEST FOR INFORMATION
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NRC Inspection Report 50-440/93018 requested the following information:
(1) a summary of the report developed to determine how existing instructions meet the intent'of the secondary containment control guideline; and (2) any corrections to the conclusions presented in previous submittals concerning secondary containment control. The
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inspection report also indicated PNPP's agreement to provide a copy of l
the final evaluation report to the NRC resident inspector's office l
onsite.
II.
EVALUATION SUMMARY
" MULTI-DISCIPLINE REVIEW 0F HOV EXISTING PERRY INSTRUCTIONS MEET THE INTENT OF THE BVROG EPG SECONDARY CONTAINMENT l
l CONTROL GUIDELINE", dated August 26, 1993 l
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Evaluation Purpose The purpose of the evaluation was to review the Perry Nuclear Power Plant (PNPP) procedures in comparison with the Boiling Vater Reactor l
Owner's Group (BVROG) Emergency Procedure Guidelines (EPG) for Secondary Containment Control (SCC), to determine the extent that l
existing plant procedures met the intent of the SCC guidelines, and to identify any procedural enhancements necessary to fully comply l
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vith the intent of the guidance.
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Evaluation Methodology To ensure comprehensive consideration of the SCC guidelines, including events involving leakage outside both the primary and secondary containment structures as requested by PNPP Safety Evaluation Report, Supplement 8 (SSER 8), the evaluation extended all assessment criteria beyond the designed secondary containment structure described in the PNPP Safety Evaluation Report (SER)
section 6.2.1.9, to include the auxiliary and intermediate buildings (including the fuel handling area), and steam tunnel which surround the primary and secondary containment structures.
The plant procedures associated with implementing the EPG guidance for secondary containment control were evaluated by performing a table-top verification of each EPG secondary containment control step to determine if and how the intent of the step was met with the existing Perry procedures. The evaluation documented for each EPG secondary containment control step:
(1) the intent or purpose of each step; (2) how this step relates to the PNPP secondary containment structures and how this step vas implemented using the existing operating instructions with regard to both the annulus and the surrounding structures; and (3) the evaluation conclusion.
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~PY-CEI/NRR-1710 L l
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Attachment 1
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Page 2 of 3 C.
Evaluation Scope
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The scope of the evaluatior included applicable Plant Administrative Procedures, System Operating Instructions, Off-Normal Instructions, Plant Emergency Instructions, Alarm Response Instructions, EPG Revision 4, the Perry Specific Technical Guideline, and~the PNPP Individual Plant Examination technical assignment files.
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Evaluation Recommendations Using the assessment criteria, the evaluation recommended revision of existing Off-Normal Instructions to identify maximum safe operating limits and provide specific operator actions to meet the specific steps of the SCC guidelines which address beyond iesign basis events.
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Procedural changes for these recommendations hav been implemented.
In addition to modification of Off-Normal Instructions, the
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evaluation recommended further consideration of the following issues:
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- Development of a process for verification and validation of supporting plant instructions which provide direction to enter the t
plant emergency instructions. This recommendation vill be
evaluated during PNPP's Emergency Operating Procedure (E0P)
Improvement Program which is described in PNPP letter dated August
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6, 1993, (PY-CEI/NRR-1684L).
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- Revision of the PSTG/EPG Deviation Sheet for EPG steps RR-1 and
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RR-2 to address extension of the secondary containment control
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assessment criteria to include the buildings surrounding
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i containment. This recommendation vill be evaluated during Perry's Emergency Operating Procedure (EOP) Improvement Program.
- Purther review of application of the SCC guideline with regard to the Perry unique secondary containment annulus design. This i
I recommendation vill be referred to the BVROG Emergency Procedures Committee.
III. CORRECTIONS TO CONCLUSIONS IN PREVIOUS SUBMITTALS
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A letter dated October 31, 1991, (PY-CEI/NRR-1405L) indicated that detailed reviews by PNPP's Operations / Engineering staff had determined that current guidance in plant procedures provided appropriate operator actions, and that the intent of the SCC guidelines was satisfied with no further changes to plant procedures.
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PY-CEI/NRR-1710L
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Attachment 1
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l The 1991 evaluation was based on broad consideration of whether the EPG Revision 4 SCC guidelines was applicable to PNPP's design and identified l
existing plant procedures vhich provided actions to accomplish the intent of the SCC guidelines.
The 1991 evaluation took into account PNPP's unique seconde +s containment design as described in SER section 6.2.1.9, and the recogni;1on by SSER 8, section 13.5.2.2.1, that the containment design accommodates the stated purpose of the EPG SCC guidelines, and that no specific SCC
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guidance was required for the areas within the secondary containment.
The evaluation addressed the SSER 8 request that PNPP consider the applicability of selected portions of the SCC guidelines for events involving leakage outside both the primary and secondary containment structures. The evaluation identified plant procedures which existed to provide operator actions to monitor and respond to radiation, temperatures and vater levels for areas outside of the secondary l
containment structure.
NRC inspection report 50-440/93007 concluded that the 1991 evaluation was l
inadequate and prompted PNPP to re-evaluate the issue. The charter of the 1993 evaluation was to perform a line-by-line review (rather than the
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broader " intent" reviews that vere performed in 1991) of the SCC
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guidelines versus PNPP procedures with regard to the SCC EPG's and determine the extent that existing plant procedures met the specific l
actions of the SCC guidance, in order to identify any procedural enhancements necessary to fully comply with the SCC guidance.
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PNPP agrees with the conclusions of IER 50-440/93007 regarding the 1991 SCC evaluation, in that additional documentation would have been appropriate to further justify that operator actions within the existing
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procedures met the broader intent of the SCC guidelines.
Based on the results of the " MULTI-DISCIPLINE REVIEV 0F H0V EXISTING
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i PERRY INSTRUCTIONS MEET THE INTENT OF THE BVROG EPG SECONDARY CONTAINMENT i
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CONTROL GUIDELINE", dated August 26, 1993, PNPP concludes at this time that procedure modifications that have been implemented per recommendations of the 1993 evaluation provide compliance with the
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specific actions of the SCC guidelines.
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