ML20028G019

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Forwards Update of Program to Resolve Concerns Raised by J Humphrey,W/Results of Completed Action Plans,Per SER Outstanding Issue 8 on Mark III Containment Sys Issues. Schedule for Completion of Unresolved Items Noted
ML20028G019
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 01/26/1983
From: Edelman M
CLEVELAND ELECTRIC ILLUMINATING CO.
To: Youngblood B
Office of Nuclear Reactor Regulation
References
PY-CEI-NRC-0007, PY-CEI-NRC-7, NUDOCS 8302070325
Download: ML20028G019 (81)


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P.O IlOX 5000 - CL EVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - lLLUVINATING BLDG -- 55 PUBLIC SQUARE l l

Serving The Best Location in the Nation l RJRRAY R. EDELMAN VICE PRESIDENT Nucud a January 26, 1983 PY-CEI/f1RC-0007 L Mr. B. J. Youngblood, Chier Licensing Branch flo. 1 Division of Licensing U. S. fluclear Hegulatory Commission Washington, D. C. 20555 Perry fluclear Power Plant Docket tJos. 50-440; 50-441 SER Outstanding Issue tio. 8 Mark III Containment System Issues

Dear Mr. Youngblood:

In our letter dated September 9,1982, we provided our program of detailed action plans to resolve the concerns raised by Mr. John Humphrey. We also committed to submit the results of the analyses required for resolution by January 17, 1983. Attachment I to this letter provides a current update of the Perry Action Plan with the recults of the action plans completed to date. Schedules for compeltion of u1 resolved items are noted.

If you have any questions concerning our program, please contact me.

Very truly yours, Murray R. Edelman Vice President tJuclear Group MRE:kh cc: Jay Silberg, Esq.

John Stefano Max Gildner

( J. Kudrick H. Pender i

Attachment l

h' 8302070325 030126

{DRADOCK 05000440 PDR

Action Plan 1 - Generic I. Issues Addressed 1.1 Presence of local encroachments such as the TIP platform, the drywell personnel airlock and the equipment and floor drain sumps may increase the pool swell velocity by as much as 20 percent.

1.2 Local encroachments in the pool may cause the bubble break-through height to be higher than expected.

1.4 Piping impact loads may be revised as a result of the higher pool swell velocity.

II. Program for Resolution 1.GE Provide details of the one-dimensional analysis which was completed and showed a 20% increase in pool velocity.

2.GE The two-dimensional model will be refined by addition of a bubble pressure model and used to show that pool swell velo-city decreases near local encroachments. The code is a ver-sion of SOLA.

3.GE The inherent conservatisms in the code and modeling assump-tions will be listed.

4.GE The modified code will be benchmarked against existing clean pool PSTF data.

5.GE A recognized authority on hydrodynamic phenomena will be re-tained to provide guidance on conduct of the analyses.

6a.GE An evaluation will be made with drawings of various plant encroachments and pool geometries to establish that the results of the Grand Gulf Analysis are representative or bounding.

6.GE The ef fects of the presence of local encroachments on pool swell will be calculated with the two-dimensional code.

Three-dimensional effects'(such as bubble break through in non-encroached pool regions) will be included based upon empirical data.

III. Schedule

! Items 1-3 are complete. Results were submitted in a letter from L. F. Dale, MP&L, to 11. R. Denton, NRC, reference #AECM-82/353, dated August 19, 1982. Additional information for Item 3 was pro-vided in a letter f rom L. F. Dale, MP&L, to li. R. Denton, NRC, roterence #AECM-82/497, dated October 22, 1982. These results apply to Perry.

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Action Plan 1 - Generic (continued)

Item 4'is complete. Results were submitted in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/497, dated October 22, 1982. These results apply to Perry.

Item 5 is complete. Results were submitted in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/574, dated December 3, 1982. These results are applicable to Perry.

Items 6a and 6 will be completed by May 29, 1983.

IV. Results to Date These items were originally intended to be completed as part of the generic effort being accomplished for the Containment Issues owners Group by General Electric. It has subsequently been determined that due to different configurations, a. plant unique analysis was required. This is currently in progress at General Electric.

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4 Action Plan 2 - Generic / Plant Specific I. Issues Addressed 1.3 Additional submerged structure loads may be applied to sub-merged structures near local encroachments.

II. Program for Resolution 1.GE The results obtained from the two-dimensional analyses com-pleted as part of the activities for Action Plan 1 will be used to define changes in fluid velocities in the suppression pool which are created by local encroachments. Supporting

arguments to verify that the results from two-dimensional analyses will be bounding with respect to velocity changes in the suppression pool will be provided.

2.GAI The new pool velocity profiles will be used to calculate re-vised submerged structure loads using the existing.or modi-ficd submerged structure load definition models.

3.GAI The newly defined submerged structure loads will be compared to the loads which were used as a design basis for equipment and structures in the Perry Nuc1 car Power Plant supppression pool.

III. Schedule Items 1-3 will be completed by May 29, 1983.

IV. Results to Date Item I was originally intended to be completed as part of the generic effort being accomplished for the Containment Issues Owners Group by General Electric. It has subsequently been determined that due to different configurations, a plant unique analysis was 4

required. This is currently in progrest at General Electric.

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Action Plan 3 - Plant Specific I. Issues Addressed 1.5 Impact loads on the HCU floor may be imparted and the HCU modules may fail which could prevent successful scram if the bubble breakthrough height. Is raised appreciably by local-encroachments.

II. Program for Resolution 1.GAI The analytical results obtained from the activities completed under Action Plan I will be evaluated.

III. Schedule i

Item 1 will be completed by May 29, 1983.

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Action Plan 4 - Generic / Plant. Specific I. Issues Addressed 1.6 Local encroachuents or the steam tunnel may cause the pool swell froth to move horizontally and apply lateral loads to the gratings around the HCU floor.

II. Program for Resolution la.GE An assessment will be made of the potential effects which variations in liCU floor support arrangement and grating location may produce. This assessment will result in the selection of a bounding arrangement for defining lateral loads.

1.GE A bounding analysis for determining the horizontal liquid and air flows created by the presence of the steam tunnel and 11C0 floor will be performed. The forces imposed on the IICU floor supports and grating will be calculated from this informa-tron.

2.GAI It will be demonstrated that the affected structures can

-withstand the calculated loads.

III. Schedule i

Items 1 and la are complete and included in this submittal. Item 2 will be completed by February 28, 1983.

IV. Results to Date Items la and 1.

A bounding, steady, potential flow analysis was performed to deter-mine the free jet slow field passing through the IICU floor. This analysis nasumed all the rising fluid passed through the liCU floor open area (i.e., no separation of liquid droplets following impact on the solid portion of the llCU floor) and velocities of the liquid and gas phases are equal.

This potential flow model was driven with the same conditions as used for calculation of a BWR 6 plant unique llCU floor differential pressure model. This model is documented in Reference 1 and assumes the pool swell froth mixture impacts on the llCU floor, stagnates, and then is reaccelerated due to wetwell pressurization.

The analysis concluded that horizontal loads on the IICU floor are small and vary with location. For beams, the horizontal force is a maximum of 0.15 psid. For grating, the horizontal force is a maximum of 0.10 psid.

Action Plan 4 - Generic / Plant Specific (continued)

Details of the load definition are given in Attachment 4.1.

The analysis which yields these results is conservative, due to the assumptions of steady flow, equal phase velocities, and stagnation of liquid droplets upon impact with solid portions of the HCU floor. In realliy, the flow is highly transient. Most of the rising two phase mixture is expected to impact the solid floor, stagnate, and fall back to the pool surface. Hence, the flow which i actually passes through the IICU floor will have total momentum substantially less than determined with this analysis. The cal-culated loads are thus expected to be bounding and very conservative.

I Reference

1. Bilanin, W. J., " Mark III Containment Analytical Model,"

l NEDO-20533, Supplement 1, June 1974.

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Attachment 4.1 I. The Perry unique liCU floor horizontal beam load is defined as:

2 AP beam, max = 0.15 lbf/in (10)

This load is to be applied to the first major radial beam (depth i greater than or equal .) 24 inches) under each grating section.

I 7his load should also be applied to minor beams located closer to the concrete sections of floor than the first major beam.

The load on major beams may be reduced as follows:

(1) The load may be reduced, linearly, from AP to beam, max zero between the first major beam and the zero shear plane.

The zero shear plane is located at:

i 4 = 180*

(All angles quoted per azimuthal coordinate system shown on Gilbert drawing D-511-023.)

i (2) For beams not directed radially outward from the reactor centerline, the pressure may be reduced by:

AP = AP cos a beam beam _ max where a is the angle between that of the subject beam and a radially outward line through the reactor centerline.

In all cases, the direction of loading is from concrete areas toward the zero shear planc.

Since the flow is assumed to stagnate between beams which extend below the IICU floor, there is no horizontal loading j under concrete areas.

II. The Perry unique IICU floor grating load is defined as:

2 AP grating = 0.10 lbf/in This load is to be applied uniformly to all vertical surfaces of all grating components.

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Action Plan 5 - Generic / Plant Specific I. Issuns Addrnssed 2.1 The annular regions between the safety relief valve linos and the drywell wall ponotration alcoves may produce condensation oscillation (C.O.) frequencien near the drywell and contain-ment wall structural resonance frequencias.

2.2 The potential condensation oscillation and chugging londa produced through the annular arna betwnen the SRVDL and alcova may apply unaccounted for londs to the SRVDL. Since the SRVDL la unsupported from the quenchor to the insido of the drywell wall, this may renuit in f ailure of the lino.

2.3 The potential condonantion oscillation and chugging londs producod through the annular nron betwoon the SRVDL and alonvo may apply unaccounted for loads to tho penetration alcovn. Tho londa may also be at or nonr the natural fro-quency of thn sloovo.

II. Progrnm for_Rnnolution I

l.GE The oxisting condennation data will be reviewod to verify that'no n.ignificant frequency shifts occurrod. Thn data will niso bo reviewed to confirm that the amplitudon worn not j clonnly related to neoustic offacts.

4 2.GE Th triving ronditions for condensation oscillation at the SRVL. exit will hn calculated. Based on theso calculations, existing test datn will ho nand to estimato the frequency nnd j hounding prennuto amplitudo of condonnation oscillation at the SRVDL nanulus oxit.

3.GAI A wide diffuronen between the C.O. frequency and atructural renonancen will bo demonstrated. Thn margin botwnnn the new londs and existing londs will ho quantified.

4. gal Provido n dotnited doncription of all hydrodynamic and thor-mal loads that aro imposed on tho SRVDL and the SRVDL ninnvn during LOCA hlowdownn.
5.GAI Annurn that thormal londs crnated by stonm flow through the annulus havn heen accounted for in thn design.

6.GAI State the external prnusurn londn which thn portion of the SRVDL nnelosed by thn sloovo can withstand, l,

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Action Plan 5 - Generic / Plant Specific (continued) l l

III. Schedule Items 1 and 2 are' complete. Results were submitted in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/574, j . dated December 3, 1982. .These'results are applicable to Perry.

i Items 3-6 are complete and included in this submittal.

IV. Final Program Results Item 3 The presence of C.O. In the SRVDL sleeve vent creates new pressure peaks at frequencies of approximately 50 Hz and 100 Hz. These frequencies are considerably above the structural resonance frequencies of 12.1 Hz for the drywell and 15.2 Hz for the contain-ment. As can be seen from the response to Item 4 below, con-siderable design margin exists to account for new C.O. loads produced at the SRVDL sleeve annulus.

Item 4 A detailed description of the hydrodynamic and thermal loads in-cluded in the design basis of _ the SRVDL piping and the SRVDL sleeve during LOCA blowdown is given below.

SRVDL Piping

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{ A. Hydrodynamic Loads During a LOCA blowdown, the worst of which being the design l basis accident, the hydrodynamic related loads affecting the SRVDL can be grouped into two (2) categories.

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1. Inertia loads caused by building excitation due to the purging of drywell air and steam into the containment air space. The loading cases considered for this category are chugging, condensation oscillation, and pool swell.
2. Suppression pool water motion loads due to the purging of drywell air and steam into the containment air

, space. The loading cases considered for this category are vent clearing, LOCA bubble load and pool fallback.

3. Loads caused by the drywell negative prassure transient.

The loading conditions considered for this category are weir drag, weir impact and weir inertia.

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Action Plan 5 - Generic / Plant Specific (continued)

B. Thermal Loads The thermal loads on the piping are based on accident temperatures of 330*F and 185'F for the drywell and sup-pression pool, respectively.

SRVDL Sleeve A. Ilydrodynamic Loads Since the sleeve is flush with the drywell wall, i.e., it does not extend into the suppression pool, the effects due to hydrodynamic loads (pool swell, condensation oscillation, chugging, SRV actuation, etc.) were negligible.

B. Thermal Loads l

The thermal loads imposed on the sleeve from steam flow through the annulus have been accounted for in the design. The sleeve temperature is assumed to be 270*F and the outside pool temperature is 90*F.

C. Other Loads i

A 10. kip axial pipe anchor load was assumed to act

[ simultaneously with the thermal loads specified in (B) above.

This is a conservative assumption since the SRVDL pipe is not L

anchored to the slcovo.

Item 5 The maximum accident ambient temperature within the drywell is 330 F. Since the normal SRV temperature, for the piping through the drywell sleeve, is 400+ *F the controlling design loads will come from the normal SRV thermal case.

Item 6 The maximum external pressure load that the SRVDL enclosed by the drywell s1covo can withstand, providing that the maximum compressive stress does not exceed yield and including a factor of safety of 2 to accoont for shock loading and piping discontinuities, is 250 psi, i

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4 Action Plan 6 - Plant Specific

I. Issues Addressed 4

i 3.1 The design of the STRIDE plant did not consider vent. clear-ing, condensation oscillation and chugging loads which might ,

be produced by the actuation of the RHR-heat exchanger' relief '

valves. '

I. 3.3 -Discharge from the RHR relief valves may produce bubble dis-

charge or other submerged structure loads on equipment in the suppression pool.

3.7 The concerns related to the RHR heat exchanger relief valve discharge lines should also be addressed for all relief lines that exhaust into the pool.

II. Program for Resolution 1.GAI The vent c1 caring loads associated with actuation of the RHR relief valves will be calculated. The water jet loads will e

also be calculated. The dynamic loads associated with re-lief valve operation will be recalculated to evaluate relief valve discharge line design.

The following information will be submitted for all relief valves which discharge to the suppression pool j 2.GAI Isometric drawings and P& ids showing line and vacuum breaker j location will be provided. This .information will include the i following: The geometry (diameter, routing, height above

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the suppression pool, etc .) of the pipe line from immediately downstream of the relief valve up to the line exit. The i

maximum and minimum expected submergence of the discharge  :

) line exit below the pool surface will be included . Also, any lines equipped with load mitigating devices (e.g.,

spargers, quenchers) will be noted.

3.GAI The range of flow rates and character of fluid (i.e., air, water, steam) which is discharged through the line and the plant conditions (e.g., pool temperatures) when discharges occur will be defined.

4.GAI The sizing and performance characteristics (including make, model, size, opening characteristics and flow characteris-

' tics) of any vacuum breakers provided for relief valve dis-charge lines will be noted.

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5.GAI The potential for oscillatory operatien of the relief valves in any given discharge line will be discussed.

4 6.GAI The potential for failure of any relief valve to reseat t

following initial or subsequent opening will be evaluated.

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i Action Plan 6 - Plant Specific (continued) 7.CAI The location of all componnnts and piping in the vicinity of the dischargo lino oxit and the design bases will be providad.

III. Schndulo 3

Items 2-7 nro complotn and included in this submittal. Item I will bn completed by Fnbruary 28, 1983.

IV. Rnsults to Datn Item 2 Sou list of attached drawings, Table 6.2-1 and attachnd drawings.

Itom 3 Son attachnd Tablo 6.3-1.

Item 4 Rolinf valvos 1.12F0250, E12F025C, and E12F055, and E12F005 common dischargo linn havn two chock valvna, E12F103B and E12F104B, in surins of vactmm rulinf.

Rolinf valves E12FC25A, E12F055A, and E21F018 common dischargn linn have two chock valvos, E12P103A and E12F104A, in scrins for vacuum rnlief, RCIC Turbino Exhaust.1. inn has two check valvos in snrios. E51F079 and E51F081, for vacuum relinf. All thron vacuum rolinf lines above tako air from containmont from a common 2-inch lino that is part of thn E51 system. Snn attached Tablo 6.4-1 for the charactoristics for the vacuum rollef chnck valvos E12F103A and !!, E12F104A and B, E51F079, and E51F081. The schematic arrangement. of tho vacuum bronkurs is shown on the rnforenced P&ID's (Act.fon Plan 6.2 Rnsponso).

Item 5 Thn RilR hunt oxchangnr relinf valvos. E12F055A nad B, could experinnca oscillatory action duo to undefinnd cyclic bnhavior of tho steam prossurn rnducing valvos E12F051A and B, which nro air oporated solonoid valvos that fait closo. The opurator on valvos E12F051 A and 11 allow the valvos to stroko full opon in approximatoly 30 snconds and stroke full closn in approximately 32 snconds, thus nny postulated oscillation would hn slow. As r.tated abovn, tho dischargn linn on thn relinf valvos is supplied with vacuum rulinf.

Item 6 Action Plan 8 will address thn failurn of RilR rnlinf valvos undnr conditions that bound all postulated failurns on the rnlinf valvns.

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. Action Plan'6 - Plant Specific (continued) 1

' Item 7 The drawings for Action Plan 62 above show all submerged piping and components in the suppression pool. The design drag loads for all ,

piping and components in the suppression pool are conservativnly based on main steam safety relief valve maximum bubble pressures and LOCA hubble pressura. Using LOCA and main steam SRV bubble i

pressures conservatively over estimates drag loads on submerged structures (sno Attachment L to Gessar Appendix 38).

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Table 6.2-1 List of Drawings for Action Plan 6 Flow Diagrams Piping' Physicals Component Drawings-

D-302-605 D-304-025 D-301-734 D-302-631 D-304-026 D-301-726 D-302-632 D-304-027 D-303-601 i

D-302-641 D-304-028 D-303-602 i D-302-642 D-304-631 4 D-302-643 D-304-632 D-302-701 D-304-634

! D-302-705 D-304-641 i D-304-642

{ D-304-643 D-304-644 D-304-645 I D-304-646 1 D-304-647 D-304-648 D-304-649

D-304-701 D-304-703 D-304-706 4

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Table 6.3-1 Relief Line Discharge to Suppression Pool - Characterization Pool (1)

Discharge Discharge Submergence Set Line Sire, Model Elev.

Description System Valve No.

Line Size (15) Lige Vol. Fluid & Pressure Operating Reference

& Make (inches) (ft ) (f t & inches) _Chara._ (psig) Capacity Mode Drawings Min./ Max.

1. RHR Pump A E12 E12F025A 1"x2" w/ll0 in 6 I3) 10.205 10.105 580'-0" waterI ') 485 36.5 gpa LPCI (5)

Discharge Line orifice; Target Relief Valve Rock Corp.

Fig. #76H-005

2. RRR Pump B E12 E12F0258 Same as Item 1. 6 0) 13.117 13.217 580'-0" Water }

485 36.5 gpa LPCI

,, Discharge Line (5)

- Relief Valve

3. RHR Pump C E12 E12F025C Same as Item 1. 6 I 12.515 12.615 580'-0" Water ('I 485 36.5 gpa LPCI (5)

Discharge Line Relief Valve 2

Steam OO)

4. RHR Heat Ex- III E12 E12F055A 4"x6" w/6.78 in 6 19.238 19.338 588'-10" 485 138.600 Steau (5) changer A orffice; Target Ibe/hr. Condensing Relief Valve Rock Corp. 76H-013 Mode
5. RHR Heat Ex- E12 E12F055R Same es f4. 6 II 23.99 24.09 588'-10" Steam (10) 485 138,600 Steam (5) chanRer B lbm/hr. Condensing Relief Valve Mode
6. RHR Shutdown E12 E12F005 1"x2" w/.110 in 6 5} 15.012 15.112 580'-0" Water IIII 185 24.4 spe Cooling (5) orifice; Target Suction Line Rock Corp.

Relief Valve #76J-005

Table 6.3-1 (continued)

Pool (1)

Discharge Discharge Sobeergence set Line Size. % del Line Sire (15) Lige Vol. Elev. Fluid & Pressure Operating Reference Descriptien Systes Yalve Ro. 4 %ks (inches) (ft ) ,(ft 4 inches) Chara. (pela) Capacitv bde Drawings Min./ Man.

7. RPCS Pump E22 E22F035 I\"x2" w/.116 in 12 42.656 43.049 $80'-0* Water 1564 114 spa Post LOCA D-302-701 Discharge orifice; Target D-304-701 Relief Yalve Rock Corp. D-304-703 Fig. #7677-012
8. LPCS Pump E21 E21F018 1\"m2" w/.785 la 6 6.365 6.495 580'-0" Water $35 267 spa Post LOCA D-302-705 Discharge orifice; Target or Sy-Pass D-304-706 Relief Talve Rock Corp. #768-007 D-304-643
D-304-647
9. RCIC Turbine E51 E51F068 I8I 12" Cate valve 12I *) 35.656 26.049 554'-7" Steam II I - 3.42x10' Rot-Standby D-302-431 Eshmast Borg-Warner ,

to 4.90n103 (RRR Sta. ' D-302-632 Fig. No. 81090 lbelhr. Cond. D-304-431 D-304-6 34 5

10. m in Steam 421 M5tv ceneral Supplied 10 to 44.9 56.1 578'-115.(2) Steam 1103 to 8.95x10 RPT Righ D-302-605 5

Relief Valves Quenchers (16) 1190 to 9.39310 Pressure D-304-015 (7) Iba/hr. to D-304-029 664/B/2/jg

l Footnotes to Table 6.3-1

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i 1. The suppression pool elevations are: High Level 593'-4", Low Level 592'-10", Bottom of Pool 574'-10".

2. Quencher outlets to suppression pool.
3. E12F025A, E12F055A, E21F018 discharge into the suppression pool through a common line.
4. E12F025B, E12F025C, E12F055B, E12F005 discharge li.to the suppression pool through a common line.
5. Referenced GAI drawings: D-302-641, D-302-642, D-302-643, D-304-641, D-304-642, D-304-643, D-304-644, D-304-645, D-304-646, D-304-647, D-304-648, D-304-649.

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6. Equipped with a discharge sparger, reference drawing D-301-726.
7. Reference drawing for quencher is D-301-734.
8. E51F068 is not a relief, but a gate isolation valve.
9. Water in the LPCI line is normally at 185 F and 163 psig; suppression pool maximum temperature is at 185 F.
10. Temperature increases from 60*F to 350 F at outlet to relief valve and decreases to 310*F at discharge to the suppression pool.

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11. Water shutdown cooling suction line is at 35 psig and 100 F.

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12. During accident conditions, the pump discharge line is at 215 psig, 185 F 4

and 7500 gpm. During bypass, the line is at 510 psig, 90*F, and 0 gpm flow.

13. Water in the IIPCS pump discharge line during post accident conditions ranges from 1255 psig to 390 spig, 185*F to 40 F with flows to 7800 gpm to 1550 gpm.
14. Steam in the RCIC turbine exhaust line ranges from 19.9 psia and 228*F and 16.6 psia and 218*F.
15. The discharge line volume is from the designated valve to the high (minimum line volume) suppression pool level or to the low (maximum line volume) suppression pool level.
16. The minimum and maximum air volumes for the SRV discharge lines is the absolute minimum or maximum based upon all 19 SPV discharge lines.

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Table 6.4-1 Vacuum Relief Check Valve Characteristics Manufacturer - Dresser Industries Figure No. - 5580 W Size and Type 1/2" Lift Check Valves Cv - 15 Flow Diameter 1/8" l

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4 Action Plan 7 - Generic I. Issues Addressed 3.2 The STRIDE design provided only nine inches of submergence above the RHR heat exchanger relief valve discharge line at low suppression pool levels.

II. Program for Resolution 1.GE The Humboldt Bay pressure suppression test data demonstrated for relationship of discharge submergence on condensation
effectiveness. An evaluation based on this data will be sub-mitted which shows that the maximum discharge from the relief valves can be quenched under all possible submergence conditions.

III. Schedule Item 1 is complete. Results were submitted in a letter from L. F.

Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/353, dated August 19, 1982. These results apply to Perry.

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Action Plan 8 - Plant Specific I. Issues Addressed 3.4 The RiiR heat exchanger relief valvo discharge lines are pro-vided with vacuum breakers to provent negativo pressure in the lines when discharging stoair is condensed in the pool.

If tho valvos experienco repen:od actuation, tho vacuum breaker sizing may not be adequate to provent drawing slugs of water back through the dischargo piping. Thoso slugs of water may apply impact loads to the roller valve or be discharged back into the pool at the next relief valvo actuation and apply impact loads to submerged structures.

3.5 The RllR rollof valvos must be capable of correctly function-ing following on upper pool dump which may increase the supprossion pool level as much as flvo foot creating higher back pressures on the relief valves.

II. Program r _for Resolution 1.GAI A failure modo nnalysis on the pressure controller to esta-blish all possiblo failuro modos will be performed.

2. gal Tho system donign will be reviewed to determino if subso-quent valvn operation is feasibin.
3. gal Based on the results of itera 2, the appropriato loads will bn determined. This will be the water jot and air bubblo load croated by a first actuation of the roller valve and either a second " pop" load based on subsequent actuation or condensation oscillation loads based on continuous vent-ing.
4. gal The vacuum breaker performance will bo quantified as appil-cablo. This will includo a calculation showing the maximum nlevation to which water can be drawn in the RilR rolfof valvo dischargo linn.
5. gal Analysos demonstrating that the heat exchangers arn capable of withstanding an overpressuro transient will be completed.

EllR rollof valves will bo demonstrated to be capable of functioning following an upper pool dump.

Ill. Scheduln Items 1&2 are completo and included in the submittal. Items 3-5 will bn completed by l'ebruary 28, 1983.

Action Plan 8 - Plant Specific (continund)

IV, Results to I)nte i t em __1 An evaluation of the failurn modes of the pressurn controllora azul valvos F051 has boon complated. The responno timo (minimum travel timo) in 30 noconds which all but precludes gonorntion of a dynamic responnn in thn suppression pool.

hem 2 linsed upon a review of tho system design subsn<pient dischargo valvo actuntion is possibln. Son responso to Action pinn 6.5.

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4 Action Plan 9 - Generic ,

I. Issues Addreseed '

! 3.6 If the RHR heat exchanger relief valves discharge steam to the upper levels of the suppression pool following a design

basis accident, they will significantly aggravate suppression
pool temperature .mtratification.

II. Program for Resolution la.GE A bounding quantity of energy which could be added to the suppression pool due to actuation of the R!lR heat exchanger relief valves will be identified. This derinition will be based upon the maximum energy addition rates due to failures *

in the Individual plant RilR pressure controllers.

1 GE An evaluation of all scenarios which could lead to discharge from the RilR heat exchanger relief valves will be made.

2.GE The discharge plume from the relief valves will be investi-gated. This plume will establish the maximum area of the pool which can be affected.

III. Schedule i

Items la and 1 are complete. Results were sulmitted in a letter I f rom L. F. Dale, HP&L, to 11. P. Denton, NRC, reference #AECM-82/497 dated Octcher 22, 1982. The results c; ply to Perry. '

Item 2 is complete. Results were submitted in a letter from L. F. Dale, HP&L, to 11. R. Denton, MRC, reference #AECH-82/574, dated December 3, 1982. These results are representative of Perry.

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Action Plan 10 - Gonoric I. Innuns Addronand 4.1 Thn prnannt. containmnnt renpon.so analyses for drywnll bronk accidnnta annumn that the ECCS syntoms transfor a significant qunntity of water from thn supprosnion pool to the townr regionn of the drywnll t.hrough thu break. This ranulta in n pool in thn drywnll which in nnanntially inointed from tha j nupprnanlon pool at. a tempornturn of approxite.toly 135 dngrnon F. Thn containment ronponnn annlysin nanumns that thn drywnll pool in thoroughly mixnd with the supprossion pool. If tho inventory in tho drywnll in annumod to hn inolnted and thn romaindor of tho hont. In dischargod to tho t

supprnnaion pool, nn incrnano in bulk pool tempornturn of

10 dngronn F may occur.

3 II. ilrogram for Honolution

1.UE A now nrnlynin will ho parformod to quantify the of fects of

' annuming t hat thn drywnll pool in complotoly inointed f rom thn suppronnion pool. All bronk ennrgy will ho added dirnctly to thn nupprosnion pool. .

!  !!I. Scheduto Itom I in complnto. Honulin worn nuhmittod in n Intton from

!.. F. Dnin, MPt.!., to 11. H. Donton, NHC, rnforenco (/AECH-82/497 dutnd Octohnr 22, 1982. Thosn ronult.n npply to Parry.

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Action Plan 11 - Generic I. Issues Addressed 4.2 The existence of the drywell pool is predicated upon contin-uous operation of the ECCS. The current emergency procedure guidelines require the operators to throttle ECCS operation to maintain vessel level below level 8. Consequently, the drywell pool may never be formed.

9.1 The current FSAR analysis is based upon continuous injection of relatively cool ECCS water into the drywell through a broken pipe following a design basis accident. The EPG's direct the operator to throttle ECCS operation to maintain reactor vessel level at about level 8. Thus, instead of releasing relatively cool ECCS water, the break will be releasing saturated steam which might produce higher con-tainment pressurizations than currently anticipated. There-fore, the drywell air which would have been drawn back into the drywell will remain in the containment and higher pres-sures will result in both the containment and the drywell.

11. Program for Resolution 1.GE Calculations will be submitted to demonstrate that failure t

to form the drywell pool will not entall adverse conse-quences. The calculations will quantify the variation of suppression pool level without formation of the drywell pool and with upper pool dump.

l 2.GE Interactions between ESF system operation and suppression pool level will be reviewed to assure that higher suppres-sion pool level will not degrade performance.

3.GE A realistic analysis of the effects of failure to recover the drywell air mass will be performed. This analysis will include the effects of containment heat sinks and the mitigating effects of containment spray.

III. Schedule Items 1-3 are complete. Results were submitted in a letter from L. F. Dale, MP&L, to II. R. Denton, NRC, reference #AECM-82/497 dated October 22, 1982. These results are representative for Perry.

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Action Plan 12 - Generic

, I. Issues Addressed 4.3 All Mark III analyses presently assume a perfectly mixed unifctm suppression pool. These analyses assume that the temperature of the suction to the RiiR heat exchangers is the same as the bulk pool temperature. In actuality, the temperature tw the lower part of the pool where the suction is located will be as r ch as 7-1/2' cooler than the bulk pool temperature. Thus, the heat transfee through the R!lR heat exchanger will be less than expected.

II. Program for_ Resolution 1.GE A study will be completed to identify and quantify the major conservatisms which have been used in the analyses of RilR suppression pool cooling performance.

! 2.GE An assessment will be provided of the maximum difference which could exist between the bulk suppression pool temp-j erature and the Ri!R heat exchanger inlet tempora;ure. Based on existing test data this assessment should show that tho l difference will be below 7-1/2"F. An analysis will be per-formed to assess the effect of this temperature difference on peak pool temperatures.

3.GE Applicable heat exchanger test data and other test data will be reviewed to provide assurance that the correct heat exchanger capacity has been used.

III. Schedula Items 1-3 are complete. Results were submitted in a letter from L. F. Dale, MP6h, to II. R. Denton, NRC, reference #AECM-82/353, dated August 19, 1982. These results apply to Perry.

25 -

i Action Plan 13 - Generic I. Issues Addressed 4.4 The long term analysis of containment pressure / temperature response assumes that the wetwell airspace is in thermal equilibrium with the suppression pool water at all times.

The calculated bulk pool temperature is used to determine the airspace temperature. If pool thermal stratification were considered, the surface temperature, which is in direct contact with the airspace, would be higher. Therefore, the airspace temperature (and pressure) would be higher.

7.1 The containment is assumed to be in thermal equilibrium with a perfectly mixed, uniform temperature suppression pool.

As noted under Topic 4, the surface temperature of the pool will be higher than the bulk pool temperature. This may produce higher than expected containment temperatures and pressures.

II. Program for Resolution 1.GE The maximum increase in bulk suppression pool temper ature '

which could occur as a result of temperature stratifitation will be determined from Action Plan 12. The maximum sup-pression pool surface temperature will be estimated based on the current understanoing of thermal stratification as contained in GESSAR. The e3ffects of this higher surface temperature on contain.nent airspace pressure and temperature will be calculated.

2.GE The conservatism inherent in assuming thermal equilibrium between the containment atmosphere and suppression pool surface will be quantified.

III. Schedule Items 1 & 2 are complete. Results were submitted in a letter from '

L. F. Dale, MP&L, to 11. R. Denton, NRC, reference #AECM-82/353, dated August 19, 1982. These results apply to Perry.

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l Action plan 14 - Generic j I. Issues Addressed l 4.5 A numhor of factors may aggravate supprossion pool thermal stratification. The chugging produced through the first row of horizontal vents will not produce any mixing from the suppression pool layers below the vent row. An upper pool dump may contribute to additional suppression pool temperatura stratification. The largo voluma of water from the upper pool further submerges NHR heat exchanger offluent dischargo which will decreano mixing of the hotter, upper regions of the pool. Finally, operation of the containment spray eliminatos the heat or.changor offluent dischargo jet which contributos to mixing, II. 1.'aggram for Resolution 1.GE Testing Information will be st.bmitted to demonstrato tho offectiveness of chugging as a mixing muchanism in the suppression pool.

III. Schinhilo This itom is comploto. Results woro nuhmitted in a lotter from

h. F. Dalo. HP&L, to 11. H. Denton, NRC, referenco #AECM-82/353, datml August 19, 1982. Those results apply to porry.

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Action igy.n 15 - Plant Specific I. Issues Addressed 4.6 The initial suppression pool temperature is assumed to be 95*f while the maximum expected service water temperature is 90*F for all GGNS accident analyses as noted in FSAR Table 6.2-50. If the service water temperature is con.sistently i

higher than expected, as occurred at Kuosheng, the RHR system may be required to operate nearly continuously in order to maintain suppression pool temperature at or below the maximum permissible value.

l II. Program for Resolution 1.GAI This item is not directly applicable to Perry. The initial suppression pool terperature used for the accident analyses is 90*F while the maximum service water temperature is 80 F.

This provides a safety factor of 2 over the GGNS values and eliminates the concern for Perry.

2.GAI A discussion of the bases and conservatisms used in defining the 80 F service water peak will be provided.

III. Schedule ,

No response is required for Item 1. Item 2 is complete aw! Included in this submittal.

IV. Final Program Results Item 2 The basis for an 80*F intake temparature for the service water and emergency service water systems from Lake Erie is discussed in l Section 2.5.3.1 of the Perry Nuclear Power Plant Environmental Report, Construction Permit Stage and depicted on Tables 2.4-162 and Figure 2.5-2 of the same report.

Additional data is presented in the Perry Nuclear Power Plant Environmental Report, Operational Stage Section 2.4 on the temperature of Lake Erie and in Tables 2.4-1 and 3.4-1 of the same report.

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i Action Plan 16 - Plant Specific I. Issues Addressed 4.7 All analyses completed for the Mark III are generic in nature and do not consider plant specific interactions of the RHR

, suppression pool duction and discharge.

4.10 Justify that the current arrangement of the discharge and suction points of the pool cooling system maximizes pool i mixing (pp. 150-155 of 5/27/82 transcript).

II. Resolution 1.GAI Specific tests performed by Acres American, Incorporated under contract to Cleve'end Electric Illuminating verified that no interactions of the RilR suppression pool suction and discharge occur and provided the design basis for the discharge nozzle arrangement; i.e., a jet angle of 55 degroos.

This angle was chosen because of the favorabic response time and steady state velocity developed with this arrangement.

Another important consideration was the absence of large dead areas when a jet angle of 55 degrees was used.

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal.

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Action Plan 17 - Generic I. Issues Addressed .

4.8 Operation of the RHR system in the containment spray mode will decrease the neat transfer coefficient through The the RHR FSAR heat exchangers due to decreased system flow.

analysis assumes a constant heat transfer rate from the suppression pool even with operation of the containment spray.

II. Program for Resolution 1.GE Additional analyses will be completed which incorporate lower RilR heat exchanger heat transfer coefficients during the period when the RHR system is in the containmen mode.

the presence of the bypass leakage capability.

2.GE The analyses performed in Item I will be repeated so that the effects of containment heat sinks can be included and quantified. The containaent spray will be assumed to be operational only when it is necessary to assure pressure control.

III. Schedule 28, 1983.

Items 1 & 2 will be completed by February 4

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Action Plan 18 - Generic I. Issues Addressed 4.9 The effect on the long term containment response and the operability of the spray system due to cycling the contain-ment sprays on and off to maximize pool cooling needs to be addressed. Also provide and justify the criteria used by the operator for switching from the containment spray mode to pool cooling mode, and back again.

5.3 Leakage from the drywell to containment will increase the temperature and pressure in the containment. The operators will have to use the containment spray in order to main-

' tain containment temperature and pressure control. Given the decreased effectiveness of the RllR system in accomplish-ing this objective in the containment spray mode, the bypass leakage may increase the cyclical duty of the containment sprays.

II. program for Responso 1.GE A criteria for transferring the RllR system from containment spray mode to suppression pool cooling mode will be devel-oped.

la.GE The number of cycles that the containment spray system may undergo will be quantified for a small break accident.

III. Schedule Items 1 & 2 will be completed by February 28, 1983.

Action Plan 19 - Generic I. Issues Addressed I

5.1 The worst case of drywell to containment bypass leakage has been established as a small break accident. An intermediate break accident will actually produce the most significant drywell to containment leakage prior to initiation of con-tainment sprays.

5.6 The test pressure of 3 psig specified for the periodic opera-tional drywell leakage rate tests does not reflect addition-al pressurization in the drywell which will result from upper pool dump. This pressure also does not reflect addi-tional drywell pressurization resulting from throttling of the ECCS to maintain vessel level which is required by the current EPGS.

9.2 The continuous steaming produced by throttling the ECCS flow will cause increased direct leakage from the drywell to the containment. This could result in increased containment

, pressures.

II. Prggram for Resolution 1.GE A complete spectrum of analyses for varying break sizes will be completed neglecting depressurization of the drywell-prior to initiation of containment sprays, but including the effects of containment heat sinks.

2.GE Analyses which will be completed will show that the allow-able leakage of Ah f R equal to 0.9 is valid for Grand Gulf and the result will be representative for Perry.

3.GE An evaluation of the need for reducing the allowable techni-cal specification limiting conditions for drywell leakage will be provided. Any revised limit would be based upon a pressure of 6 psig la the drywell which would reflect the additional pressure produced by upper pool dump. In the evaluation, credit will be taken for drywell and containment heat sinks.

t III. Schedule Items 1-3 will be completed by February 28, 1983.

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Act.fon Plan 20 a Plant Spncific I. Janunn Aildrennnd 5.4 littnet tankngo f rom tlin tirywnll to tlin containmont may ilin- ,

nipote liydrogon outnido tlin rngion wiinan Llin liyilrognn rncom- '

lainnrn taka nuction. Tlin anticipntad lenkngn axcenda tlin capncity of tlin drywnll purgo conipinanorm. Tliin could Innd to pocknting of Isyilrogon wlif eli axenndn tlin conenntration limit of 4% lay volumn.

II. I's ogrnm f o r _linno i n,tlor!

1.0Al Thn total allownlein lainkaan will ten nonumnd to len aninnned from thn nInctilent ponntintionn. Thn potantial for pocknt-Ing of hyilrogon whicli in contninnd in thin Inn >ngn will len a

tnyjnweial.

$ 111. Hf hnelulo linm I will bn compintnd I,y l>nbrunry 28, 19 4 't .

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. - , . . , . . . , , . - - , , . - , - . . . . . , . - . . _ _ - . . , _ - , . _ , - , , . _ . - - ~ . . _ , , - . _ - _ . - - ~ . . - - . .

l Act.fon_ Plan 21 - Plant Specific I. _Innunn Addressed l

S.5 Equipmnnt may bn expound to local condit.f onn which excend t.hn I onvironmental qualificnLion nnvolopn an a ranult of direct drywnll to contnJnmont hypann lankagn.

II. Projgram for Itenolut.lon 1.GAI A lint. of essential equipmnnt locat.nd nonr cloctrical penn-t.rn t ions in tho drywnll wall will bo provided. Thn lint. will includo a qualitativo annonnmont of thn equipment.'s sonnit.ivit.y to temperaturn and the distanco of thn nquipment.

from the drywnll wall.

III. Schedulu ltem 1 ' compl.nto and included in t his submittal.

IV. [inni Program i<nnults Following both n I.0CA or n small bronk accident, tho drywnll tempornturn envolopn in highnr than t.hn contninmont.. The nunnmed I

drywnll hypann Innkago pati in via thn drywnll olect.rient punntra-

t. l on s . Tho anfoty-rn!nted equipment which may bn sufficient.ly nonr tho drywnll wall to bn afincted by highor local temporaturen nonr thosn penntrat.f ons in provided in Tablo 21.1-1. The maximum dit.tancn from thn penntrat.fons considered was 20 font. Actual distancos nro provided for ench item. An annont.mont of thn nquip-ment 'n sonn it ivi t.y to Len.pornt. urn in ntno provided in the "Qunlifica-l tlon" column.

All nnfoty-rnlated equipment and cablo located within fivn font of the drywn)1 penotrat.fons in qualifled to perform its nnfety function for t.hn drywnll temperaturn profilo.

Equipment. further than five font from thn drywell ponont.rntion in, in genorni, also qualif f nd to perform its nnfety function for thn drywnlI t.emperaturn prof f In, except as noted in Tablo 21.1-1. I t.

has been dotormined that. those equipmnnt items not. qualifind for thn drywnll tempornturn profilo nro qualif f nd to perform thnir nnfnty function for the containment. t.cmporaturn profiln with margin in accordancn with NUl<EG 0588, Catogary I . Tbnfr exact locnLion in tolation to the drywnll penetrationn has boon reviewod to dotorminn that they arn a minimum fivo font from the drywnl! ponotrations and on or below thn ulovat.lon of thn drywnll ponnt rations. This minimum spacing will ho morn than sufficient. to diffuso any warmor air filtoring through the fivn-luch conduits filled with cnbla in tho fivn-foot thick drywn!I wal1. In additlon, thn drywelI wal1 and drywnll penetration boxnn will act. as a hont. sink which will decronan thn innkago temperaturn.

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Table 21.1-1 i

Safety-Related Equipment Near the Drywell Electrical Penetrations DW Equipment Penet. Minimum 1 MPL No. Description SPEC Block Distance Qualification l

! A. Distance greater than 10 feet (Less than 20 feet max.)

C41-C001A Standby Liquid 301 4 16' At or below penetra-Control System tion elevation Pump C41-F004B SLC . Squib Valve 301 4 14' At or below penetra-tion elevation

, C41-N004B SLC Pump Disch. 301 4 14' Qualified to DW Temp-Press. Xmtr. erature Profile E12-F028B MOV 521- 4 .16 ' Qualified to DW Temp-

, 02 erature Profile i

E12-F042B MOV 521- 2 18' Qualified to DW Temp-02 erature Profile G43-F040B MOV 524 4 12' Qualified to DW Temp-erature Profile ll22-P011 SLC System 301 3 18' Below elevetion and 3 Local Panel not in line with penetrations 1

j II22-P071 Rod Position 301 1 11' 5 ft. below penetra-3 MUX Panel tion minimum eleva-

tion l R72-5001 Containment 563 3 15' At or below penetra-4 thru S029 Vessel Elect. tion olevation j Penetrations B. Distance greater than 5 ft. but less than 10 ft.

IC41-C001B Standby Liquid 301 4 8' At or below penetra-Control System tion elevation Pump 1C41-F004A SLC Squib Valve 301 4 6' At or below penetra-i tion elevation l

1C41-N004A SLC Pump Disch. 301 4 6' Qualified to DW Temp-Press. Xmtr. erature Profile 1

_. - - _ _ . . _ . ~ . _ . _ _- - . . _ _ _ . _ ._. _ , , , . . , _ _ _ , _ , _ , - . ~ - - . _ , - . - , , . ~

Tabin 21.1-1 (continund)

DW Equipment Ponot. Minimum MPL No. Description SPEC Illock Dintance thaliffention B. Distanco grnator than 5 ft, bus insa than 10 ft. (continund)

IM14-F055A Buttorfly Valvo 641 1 8' Qualified to DW Temp-eraturn Profile IM14-N057A Limit Switch 793- 1 8' Qun11 find to DW Temp-05 eraturn Profilo IM14 -F05511 Iluttorfly Valvo 641 1 8' Qualifind to DW Temp-nraturn Profilo IM14-F05711 Limit Switch 793- 1 8' Qualified to DW Temp-i 05 nrnturn Profilo IM14-F060A 11utterfly Valvo 641 2 8' Qualified to DW Temp-oraturn Proillo IH14-N062A Limit Switch 793- 2 8' Qualified to DW Temp-05 nrnturn Profiln 4

1M14-F060ll !!utterfly Valvo 641 2 8' Qualified to DW Temp-oraturn Profilo IM14-N062il Limit Switch 793- 1 8' Qualified to DW Temp-05 nraturn Profiin lH16-F010A MOV 641 1 8' Qun11 fled to DW Tnmp-erature Profilo IM16-F020A Check Volvo 635 1 8' Qualifind to DW Temp-oraturn Profilo Ill22-PO41 Main Stm. Flow 301 2 6' 5 ft. below ponotra-Instr. Hack tion minimum clova-4 -

tion, all instruments qua1ifind to DW tempornturn prof 11o lil22-P042 Main Stm. Flow 301 1 8' 5 ft, bnlow ponntra-Instr. Hack tion minimum nlova-tion, all instruments qualifind to DW temp-nrnturn proffin lil22-l'072 Hod Position 301 2 6' 5 ft. below penntra-MUX Panni tion minimum clevn-tion I

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' Table 21.1-1 (continued)

! DW Equipment Penet. Minimum MPI,No. Description SPEC Block Distance Qualification

{

C. Distance less than or equal to 5 ft.

i IM16-F010B MOV 641 2 3' Qualified to DW Temp-

} erature Profile i

, IM16-F020B MOV 635 2 3' Qualified to DW Temp-

] erature Profile l

j lil22-P005 Instr. Rack 301 1 5' 5 ft. below penetra-tion minimum eleva-tion, all instruments quallflod to DW temp-erature profile.

Ill22-P026 Instr. Rack 301 2 5' 5 ft. below penetra-tion minimum eleva-tion, all instruments qualified to DW temperature profile.

III22-P009 Instr. Rack 301 2 5' 5 ft. below penetra-tion minimum eleva-j tion, all instruments i

qualified to DW temp-erature profile.

IP57-F020A MOV 531- 2 5' Qualified to DW Temp-06 erature Profile l

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Action Plan 22 - Generic / Plant Specific I. Issues Addressed 5.8 The possibility of high temperatures in the drywell without reaching the 2 psig high pressure scram level because of bypass leakage through the drywall wall should be addressed.

II. Program for Resolution 1.GE A new analysis will be performed using the capability bypass leakage. This analysis will show that a temperature of 330*F is not reached in the drywell until after ten minutes. In this interval, the operator will have received sufficient information to manually scram the reactor.

2.GAI A detailed list of alarms and parameter displays will be developed which inform the operator of conditions in the drywell. This will include drywell cooling performance,  !

temperature, airflows, Icak detection, etc.

III. Schedule Item I is complete. Results were submitted in a letter from L. F. Dale, MP&L, to II. R. Denton, NRC, reference #AECM-82/874, dated December 3, 1982. These results are representative for Perry.

Item 2 is complete and included in this submittal.

IV. Final Program Results 1

item 2 l Considerable instrumentation is provided to inform the operator of high drywell temperature conditions. This instrumentation enables the operator to determine whethnr the high temperature is caused by an llVAC failure or a small reactor coolant leak.

There are a total of 27 temperature measurements in the drywell. As part of the containment atmosphere monitoring systems, six safety-related measurements of drywell temperature are provided.

These are divided into two redundant channels. Each channel provides recording, indication and alarming of three temperatures in the control room. The drywell cooling system provides indication, recording, and high alarming in the control room for six duct temperatures, twelve zone temperatures and three refueling belows temperatures for the.drywell.

Also, ac part of the containment atmosphere monitoring system, drywell pressure is monitored with two safety-related channels.

Each channel has both a wide and narrow range measurement which are indicated and recorded in the control rocm. The narrow range measurement is alarmed in the control room on high pressure.

Action Plan 22 - Generic / Plant Specific (continued)

In addition to the above, one separate channel of drywell pressure and temperature are indicated and recorded on the remote shutdown panel.

The range of the drywell safety-related temperature measurements are 4

50 to 350'F with high alarms at 155'F. The temperature measurements provided in the drywell cooling system are scaled 60 to 200*F with the alarms at various locations ranging from 100 to 185*F depending 1

on expected temperatures at each location. The narrow range drywell pressure has a range of 10 to 20 psia with high alarm at 15.2 psia.

The wide range pressure is -15 to 35 psi.

In addition to high temperature, there are other indications avail-able which alert the operator to a small reactor coolant leak in the drywell. Drywell floor drain sump 1cvel and level fill-up rate are recorded in the control room. An alarm is actuated when the sump fill rate exceeds 5 gal /ndn. Drywell floor and equipment drain sump pumps are equipped with timers which actuate alarms when the time required to fill the sump between pumring cycles is short enough to he indicative of a leak or the time required to pump out the sump is long enough to be indicative of a leak. Condensate flow from the drywell coolers, which is indicative of steam condensing from a leak, is inidcated in the control room and actuates an alarm when flow exceeds 5 gal / min. All of these alarms are in the control room.

The drywell atmosphere is continuously monitored for particulate, lodine, and noble gas activity. These parameters are recorded in the control room and initiate alarms in the control room when they increase significantly above background levels.

In addition to drywell high temperature, other means are provided to alert the operator to a failure in the drywell cooling system. The run-stop status of drywell cooling fans are displayed in the control room by indicating lights. All six fans are alarmed in the control room when low flow is detected with the fan energized. The temperature inlet and outlet of the drywell cooler'r, cooling water is recorded in the control room.

The indications available to the operator provide a straightforward means for determining whether a drywell temperature increase is caused by a reactor coolant leak or drywell cooler failure. A reactor coolant leak will cause an increase in drywell radio-activity, an increase in cooler condensate drain flow, and an increase in sump level fill-up rate and sump pump use, whereas a drywell cooler failure will not. A reactor coolant leak will cause an increase in drywell cooler load as indicated by greater dif-ferential temperatures, whereas a drywell cooler failure will i produce smaller differential temperature. It is possible that a l tube leak in a drywell cooler would produce an increase in cooler l drain flow along with increased flows to the floor drain sump.

l y _ . _ _ _ - _ _ _ - , _ . _ - - _ . . . _ - - . - . _

Action Plan 22 - Generic / Plant Specific (continued)

However, the affected cooler would also have a reduced air side differential temperature, whereas a reactor coolant leak will cause an increased cooler air side differential temperature. In addition, small increases in narrow range drywell pressure which are recorded and alarmed in the control room, in conjunction with other parameters, may indicate reactor coolant leakage as differentiated from drywell cooler failures.

It can, therof, ore, be concluded that adequate instrumentation has been provided to alert the operator to high drywell temperature and to allow him to determine the cause of the high temperature.

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Action Plan 23 - Plant Specific I. Issues Addressed 6.3 The recombiners may produce " hot spots" near the recombiner exhausts which might exceed the environmental qualification envelope or the containment design temperature.

6.5 Discuss the possibility of local temperatures due to recom-biner operation being higher than the temperature qualifi-cation profiles for equipment in the region around and above the recombiners. State what instructions, if any, are avail-able to the operator to actuate containment sprays to keep this temperature below design values.

II. Program for Resolution 1.GAI Arrangement drawings for the region above the recombiner ex-hausts will be reviewed. This review will demonstrate that no essential equipment can be affected by the recombiner thermal plume.

III. Schedule Item 1 is complete and included in this submittal.

IV. Final Program Resul,

The following attached layout drawings demonstrate that there is no essential equipment in the vicinity immediately above the Hydrogen Recombiners that can be adversely affected by the thermal exhaust plume from the recombiners:

Drawings Remarks E-001-057, Rev. 15 Shows the level the H 2 Recombiners are located Elev. 664'-7" f E-001-062, Rev. 18 Above Elev. 689'-6" E-001-064, Rev. 1 Above Elev. 721'-0" E-001-065, Rev. 1 Above Elev. 757'-0" E-002-002, Rev. 14 Sections of the Reactor Building, Unit 1 -

l E-002-003, Rev. 13 Sections of the Reactor l Building, Unit 2

i Action _ Plan 24 - Generic _

1. Innunn_Addrnannd 7.2 Thn computnr codo unnd by Ganorn! Electric to calculatn nnvironmental qualification paramntorn conaldern hont trans-for from thn supprannion pool surface to the containment atmosphorn. This in not in accordanco with tho axisting i licanning hasta for Mark III anvironmental qualification.

Addit.fonally, thn bulk nupprasnion pool tomparaturn was unnd in thn analynis inntend of the suppronnion pool surface

, inmporaturn.

II. ,Progr,nm_for Resolutton i

l.GE A list and justification of tho annumptienn unnd in calcu-

[ lating thn navironmontal qualification paramotorm for thn containmnnt. nir npaco will bo providnd.

!  !!!. .9chnduln This itom in completo. Rnnults worn submittnd in n Inttor f rom l I., F. linin , t!Pl.i., to 11. k. !)nnton, NRG, rufurancu //AECtl-t!2/353, dated August 19, 19112. The Grnnd Gulf conclusionn arn npplicabin j to Pnrry.

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4 Action Plan 25 - Generic / Plant Specific

1. Issues Addressed 8.1 This issue is based on consideration that some technical specifications allow operation at parameter values that differ from the values used in assumptions for FSAR trans-1ent analyses. Normally analyses are done assuming a nomi-nal containment pressure equal to ambient (0 psig) a temp-erature near maximum operating (90*F) and do not limit the drywell pressure equal to the containment pressure. The technical specifications permit operation under conditions '

such as a positive containment pressure (1.5 psig), tempera-tures less than maximum (60 or 70*F) and drywell pressure can be negative with respect to the containment (-0.5 psid).

All of these differences would result in transient response different than the FSAR descriptions.

4 II. Program for Resolution 1.GE A detailed summary of all conservatisms which currently exist in the containment response analyses which are part of the FSAR will be provided. Conservatisms in the sup-pression pool temperature analysis will be identified in Action Plan 12.

2.GE An end point analysis will be completed to demonstrate that with all initial containment parameters at worst caso values, the containment design pressure is still not signi-ficantly exceeded.

3.GE Perform an analysis with worst case values taking credit for realistic temperature differences between containment and suppression pool and the containment heat sinks.

4.CEI A complete review of the technical specifications for con-tainment conditions versus accident analysis assumptions will be made. A comparison of technical specification values and values used as initial assumptions in the acci-dont analysis will be submitted.

III. Schedule Items 1 and 3 are complete. Results for Item I were submitted in a letter from L. F. Dale, MP&L, to 11. R. Denton, NkC, reference

  1. AECM-82/353, date August 19, 1982. Results for Item 3 were sub-mitted in a letter from L. F. Dale, MP&L, to 11. R. Denton, NRC, reference #AECM-82/574, dated December 3, 1982. These results are representative for Perry.

Items 2 and 4 will be completed by February 28, 1983.

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Action Plan 26 - Plant Specific I. Issues Addressed 8.2 The draft GGNS technical specifications permit operation of the plant with containment pressure ranging between 0 and

-2 psig. Initiation of containment spray at a pressure of

-2 psig may reduce the containment pressure by an additienal 2 psig which could lead to buckling and failures in the containment liner plate, i 3.3 If the containment is maintained at -2 psig, the top row of vents could admit blewdown to the suppression pool during an SBA without a LOCA signal being developed.

II. Resolution

1. Thesu issues are not applicable to Perry. Technical speci-fication limitations for containment pressure will be developed based on the results of the analysis from Action Plan 27.

III. Schedule Based on the above response, this item is complete with this submittal.

, , --- - ---. ----e - - - - . , , - . . - - . - , ,,-n ,,y y n. .--,...n-g ,

Action Plan _27 - Plant Speciff, I. Issues Addressed 8.4 Describe all of the possible methods both before and after an accident of creating a condition of low air mass inside the containment. Discuss the effects on the containment design external pressure of actuating the containment sprays.

l II. Program for Resolution

, 1.GAI A complete lis- of scenarios which might result in reduced

! containment als mass will be developed.

2.GAI The list of sce: Trios developed in Item I will be reviewed and a worst c'. bounding scenario will be selected.

3.GAI An analysis will be completed to establish the containment response under the bounding scenario.

III. Schedule Items 1-3 are complete and included in this submittal.

IV. Final Program Results I tems _1_-3 4

The following scenarios are based upon Perry plant specific condi-tions. The containment vacuum relief (CVR) system prevents initial containment depressurization beyond the containment vacuum breaker setpoint of -0.1 psig. Therefore, scenarios such as loss of contain- <

ment ilVAC with containment purge, or upper pool dump with the operation of the drywell purge compressors are bounded by the follow analyses:

If the containment spray system is activated during any period of time other than when it is designed to be operated, it is possible that a vacuum could be created inside the containment vessel. If the containment spray system is accidently activated, an excessive vacuum is prevented from developing by means of vacuum breakers provided for this purpose.

Containment vacuum relief capability is necessary only to maintain containment integrity should the containment spray system be operated incorrectly in such a way as to *end to create a vacuum inside con-tainment. Although the containment spray syster, is adequately protected against inadvertent, unintentional, or incorrect operation by interlocks and administrative procedures. Two hypothetical situations are considered, assuming these protective measures are bypassed in some manner and the spray is started at the wrong time:

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5 Action Plan 27 - Plant Specific (continund)

A. For the first attuation, prosaurn and t'emperaturn conditions for the containmont atmospharc ara bannd on the following snquencn of events:,

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1. The atmonphorn insido containmont in at normal prennurn and tempuraturn.
2. A 6-inch rnactor water clennup (RWCU) lino break occurn insido containment.

, 3. Inointion of thn RWCU linn in compinto at 40 noconda aftor thn accident. At thin tima, the containment pronsurn in 5 psig, tempornt. urn in 157'F, and the con-6 tainment has hann isolated.

4. The vacuum bronknra betwoon thn containmnnt and drywnll

, open to equalizn thn prennurn of thu containment and j drywnll. During thin prnanuro nqualization porlod, n

portion of thn containment air in nwnpt into the j drywnll through thn drywnli vacuum brnakern and remainn j thorn when thn vacuum breakura clonn.

4 The maximum amount. of air drawn into tho drywnll from a

containment. In nimply the diffornnce butwnnn thn amount of air in containmont during normal oporation and thn amount of air in containmont aftnr thn RWCU lino inoln-tion, ant.uming n nlight.ly conanrvat.svn relativo humidit y of 100 porcent.

Normal RWCU Opornting I,i nn Conditions Isolation Pronnurn (pnig) 0.0 5.0 Tempornturn ("F) 90.0 157.0 Rnintivo 50.0 100.0 Humidity (%)

, Mnun of Air (Ibm) 82,200.0 78,100.0

5. The containmont spray nyntem in activated (dun to

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operator nrror) at a maximum flow ratn fo 10.500 gpm and a tempornturn of 60*F (minimum suppronsion pool tempornturn).

6. Thn containment in deprnnnurized an a result of stonm heing condonand by thn contninmont sprny; thn spray dropinta nrn nr.numed to havn an of ficiency of 100 por-cent. Thron canns arn considornd:

Action Plan 27 - Plant Specific (continued)

a. Condensation rate including heat transfer structures with initial temperature of 80*F.

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b. Condensation rate including heat transfer structures with initial temperature of 90*F.
c. The effects of the internal surfaces on the con-i densation rate are not considered. This is the Ifmiting casa.

The resulting pressure-temperature history within con-tainment is calculated using the digital computer code CONTEMPT ( ).

The net effect of considering the internal surfaces is a lesser vacuum condition than when the effects of the I

internal surfaces are not considered. The peak vacuum calculated is 0.70 psig. For Case c.

B. For the second case it is assumed that the containment depressurization is a result of accidental initiation of the containment spray system during normal plant operation. The conditions present in the containment at the time of spray initiation are chosen to provide the most conservation results:

1. Maximum temperature in containment during normal operation - 105*F.
2. Minimum elative humidity in containment during normal operation - 30 percent.
3. Minimum spray water temperature - 60*F.

The source for the containment spray system water is the suppression pool. The noraml water temperature in the pool is 90*F or equal to the noraml operating temp-i erature in the containment vessel outside the drywell.

The minimum temperature of 60*F for the suppression pool is based on the minimum ambient air temperature

' (60*F) in the drywell and containment vessel which would occur only under shutdown conditions. The reactor building ventilation system is designed to assure that the temperature of the containment >

atmosphere never falls below 60*F.

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Action Plan 27 - Plant Specific (continued)

4. -Spray system flow rate - 10,500 gpm It is conservatively assumed that both spray trains are actuated simultaneously. A 90-second. delay between actuation of the containment spray loops is incorporated in the Perry design and this will prov'ent simultaneous actuation.

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5. Containment pressure - (-0.1 psig)

This is the containment vacuum breaker setpoint which conservatively minimizes containment air mass (77,900 ibm).

6. Containment vacuum breakers - 3 During normal plant operation the containment vacuum relief (CVR) system outer isolation valves are open.

Therefore, it is conservatively assumed that one (1) containment vacuum breaker fails to open. Flow losses through the CVR system are included in these analyses.

7. During the evaporative cooling phase of the transient, the water drops sprayed into the containment absorb heat from the containment atmosphere and evaporate to contribute to saturating the containment atmosphere.

This process is generally very rapid for spray rates typical of containment spray systems, and therefore, the time to complete the evaporative cooling process is important to compare to the vacuum breaker response time. In the calculations presented here the following assumptions are made:

a. Spray efficiency is 100 percent.
b. All of the spray water entering the containment is immediately vaporized and forms a homogeneous mixture with the containment atmosphere. Because of this conservative assumption, no detailed analytical heat / mass transfer modeling of the spray droplets is required.
c. No heat is transferred back into the containment atmosphere from the structures during the transient.

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Action Plan 27 - Plant Specific (continued)

8. Outside air initial conditions - Temperature -5*F, 100% RH This minimum external temperature for air addition through the vacuum breakers maximizes the containment vacuum.

The peak vacuum calculated for the above worst case scenario is 0.76 psig. Therefore, it can be concluded that the containment design vacuum of 0.8 psig is acceptable.

Reference

1. Wheat, L. L., et al., " CONTEMPT-LT - A Computer Program for Predicting

. Containment Pressure Temperature Response to a Lcss-of-Coolent Accident,"

ANCR-1219, June 1975.

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Action Plan 28 - Plant Specific I. Issues Addressed 9.3 It appears that some confusion exists as to whether SBA's and stuck open SRV accidents are treated as transients or design basis accidents Clarify how they are treated and indicate whether the in.tial conditions were set at nominal or licensing values.

II. Program for Resolution 1.GAI Documentation confirming how the small break accident and the stuck open relief valve transient were treated in the design, and the values for the initial conditions will be submitted.

III. Schedule Item 1 is complete and included in this submittal.

IV. iinal Program Results Item 1 Subsection NE of ASME CODE Section III is used to determine allowable stresses for the containment vessel.

The ASME CODE considers all accidents as a design condition. The Small Break Accident (SBA) is considered a design basis condition, therefore no increase in allowable stress is permitted.

The stuck open Safety Relief Valve (SRV) transient has been con-sidered a design basis for containment design, therefore no increase in allowable si.ress is permitted.

T'+ 1re fore , in the Perry design both the SBA and stuck open SRV have buon treated as design basis accidents.

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Action Plan 29 - Plant Specific I. Issues Addressed 10.1 The suppression pool may overflow from the weir wall when the upper pool is dumped into the suppression pool. Alternately, negative pressure between the drywell and the containment which occurs as a result of normal operation or sudden con-tainment pressurization could produce similar overflow. Any cold water spilling into the drywell and striking hot equip-ment may produce therma? failures.

II. Program for Resolution 1.GAI An evaluation is being performed to determine if drywell flooding can occur following upper pool dump using the most pessimistic initial conditions during normal plant operation.

2.GAI If the analysis indicates weir wall overflow can occur, a revised analysis will be performed based upon changing the vacuum breaker setpoint, or upper pool level or a combination of the above. ~

III. Schedule Items 1 and 2 are complete and included in this submittal.

IV. Final Program Results Items 1 and 2 A drywell flooding, following upper pool dump, elevation has been performed using the worst case initial conditions during normal plant operation. Bcsed upon the results of this evaluation, the following changes were initiated:

1) Change the Upper Level Setpoints:

, New Level Original Level High Water Level 688'-33" 688'-8" Low Water Level 687'-11)" 688'-4"

11) Reduce the drywell vacuum relief valve setpoint from (-)

0.2 psid to (-) 0.15 psid.

iii) Reduce the High Water Level in the suppression pool from 593'-li" to 593'-i".

Using the above " worst case" initial conditions, the analysis confirms that drywell flooding will not occur following upper pool dump during normal plant operation.

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Action Plan 30 - Generic I. Issues Addressed 10.2 Describe the interface requirement (A-42) (sic) that speci-fies that no flooding of the drywell shall occur. Describe your intended methods to following this interface or justify ignoring this requirement. .

II. Program for Resolution The wording and interpretation of this requirement which was used to assure no flooding of the drywell will be submitted.

III. Schedule This item is complete. Results were submitted in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/353, dated August 19, 1982. These results apply to Perry.

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Action Plan 31 - Generic / Plant Specific I. Issues Addressed 11.0 Mark III load definitions are based upon the levels in the suppression pool and the drywell weir annulus being the same.

The GGNS technical specifications permit elevation dif-ferences between these pools. This may effect load defini-tion for vent clearing.

II. Program for Resolution -

la.GE An evaluation of maximum elevation differences which can exist between the weir annulus and the suppression pool will be made for each owner. If these elevation variations are outside the parameters established for GGNS, a bounding set of parameters will be defined.

2.GAI A discussion will be given of how pressure dif ferences be-tween the wetwell and the drywell will be controlled.

3.GE The changes in hydrodynamic loads which may result from these pressure differences will be evaluated.

III. Schedule Items la-3 are complete and included in this submittal.

IV. Final Program Results Items la and 3 An analysis was performed using a differential pressure between the drywell and containment air space, AP dw-ww, wi hin the nominal range: .05 5 AP 5 +3.0 psid.

dw-ww If the drywell pressure is greater than the containment air space pressure, the water level in the weir annulus iw11 be depressed and thus the liquid inertia above the top vent will be reduced. This will cause top vent clearing to occur earlier, which implies the drywell pressure at top vent clearing, and also peak drywell pressure will be less than the FSAR values. The lower driving pressures decrease the pool swell velocities, accelerations and

loads.

If, on the other hand, the initial containment air space pressure is greater than the initial drywell pressure, top vent clearing would be delayed which would increased the peak drywell pressure. An analysis was performed to determine the upper limit of this effect i

for the Perry Nuclear Power Station when the AP is -0.5 psid.

dw-ww s

Action Plan 31 - Generic / Plant Specific (continued)

This corresponds to the water in the weir annulus being elevated by almost 14 inches. The effect of this pressure difference is to delay top vent clearing by ~0.04 sec and increase the drywell pressure at the time of top vent clearing by 0.2 psi, The peak drywell pressure is increased by ~.4 psi.

The changes in the drywell pressure change the driving conditions for submerged structure bubble loads and pool swell. The changes are small, however. Taking the ratio of the drywell pressure increase due to the deeper weir annulus submergence (0.4 psi) to the drywell peak pressure (20 psid), it may be seen that the change is about 2%, c1carly a negligible change.

As a result of Action Plan 29, the drywell vacuum breaker setpoint was changed to -0.15 psid. This would considerably reduce the peak drywell pressure increase calculated above.

Item 2 i

The negative pressure condition in drywell is automatically con-trolled by the Drywell Vacuum Relief (DVR) valves (M16-F020A and M16-F020B). These 10-inch valves are set to open at (-) 0.15 psid

[ full open (-) 0.5 psid] to equalize the pressure between the drywell and containment. There are no automatic provisions to relieve pressure in the drywell, beyond the clearing of the first vents in the drywell wall.

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Action Plan 32 - Generic I. Issues Addressed 14.0 A failure in the check valve in the LPCI line to the reactor vessel could result in direct leakage from the pressure vessel to the containment atmosphere. This leakage might occur as the LPCI motor operated isolation valve is closing and the motor operated isolation valve in the containment spray line is opening. This could produce unanticipated increases in the containment spray.

II. Program for Resolution 1.GE The potential effect of maximum backflow which can occur will be estimated. This will include calculating the maximum backflow which can occur, evaluating thermal interaction with the relatively cool RHR spray flow and estimates of the limitations on flashing created by flow through the spray nozzles.

III. Schedule Item 1 is complete. Results were submitted in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM/82-497 dated October 22, 1982. These results are representative for Perry.

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l Action Plan 33 - Plant Specific '

I. Issue Addressed 16.0 Some of the suppression pool temperature sensors are located (by GE recommendation) 3" to 12" below the pool surface to provide early warning of high pool temperature. However, if the suppression pool is drawn down below the level of the temperature sensors, the operator could be misled by erron-cous readings and required safety action could be delayed.

II. Resolution 1.CEI The emergency operating procedures will require that the operator monitor both level in the suppression pool and suppression pool temperature concurrently.

III. Schedule Based upon the above response, this item is considered closed for

, Perry with this submittal.

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  • Action Plan 34 - Generic I. Issues Addressed 19.1 The chugging loads were originally defined on the basis of 7.5 feet of submergence over the drywell to suppression pool vents. Following an upper pool dump, the submergence will actually be 12 feet which may effect chugging loads.

II. Program for Resolution 1.GE The mass flux through the horizontal vents as a function of time during the postulated design basis accident will be established. A table showing submergence versus mass flux will be prepared.

2.GE Test data will be used to demonstrate that chugging loads decrease with lower mass flux and air content.

3.GE The maximum bounding effect of vent submergence on chugging loads will be quantified, and it will be shown that suffi-cient margin exists in the current load definition to bound any changed vent submergence conditions.

III. Schedule Items 1 to 3 are complete. Results.for Items 1 and 2 were submitted in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference

  1. AECM-82/497, dated October 22, 1982. Results for Item 3 were sub-mitted in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/574, dated December 3, 1982. The results are applicable to Perry.

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Action Plan 35 - Generic Issues Addressed I.

19.2. The effect of local encroachments on chugging loads needs to be addressed.

II. Program for Resolution 1.GE An evaluation of the adequacy of available models to inves-tigate the impact of longer acoustic paths on chugging load definition will be performed.

2.GE The inertial impedance effect on chugging loads will be quantified to the maximum extent possible.

III. Schedule Items 1 and 2 are complete. Results were submitted in a letter from L. F. Dale, MP&L, to !!.-R. Denton, NRC, reference #AECM-82/497, dated October 22, 1982. The results are applicable to Perry.

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l Action Plan 36 - Generic

I. Issue Addressed
20. Loads on Structures Piping and Equipment in the Drywell During Reflood During the latter stages of a LOCA, ECCS overflow from the primary system can cause drywell depressurization and vent backflow. The GESSAR defines vent backflow vertical impinge-ment and drar loads, to be applied co drywell structures, piping, and .4uipment, but no horizontal loading is speci-fled.

II. Resolution No action is required based on discussion between MP&L and the NRC staff. The basis for this decision is applicable to Perry.

III. Schedule This item is complete. Results were submitted in a letter from L.

F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/353, dated August 19, 1982. These results apply to Perry.

Action Plan 37 - Generic I. Issues Addressed 22.0 The EPG's currently in existence have been prepared with the intent of coping with degraded core accidents. They may contain requirements conflicting with design basis accident conditions. Someone needs to carefully review the EPG's to assure that they do not conflict with the expected course of the design basis accident.

II. Program for Resolution

1. The development program through which the emergency procedure guidelines have passed has adequately addressed this concern.

As a result of this issue, the Mark III owners have brought this concern to the attention of the BWR owners group. A generic resolution of this issue will be pursued with the BWR 4

owners group.

III. Schndule Based on the above response, this item is complete with this submittal.

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Action Plan 38 - Plant Specific I. Issue Addressed 6.2 General Electric has recommended that an interlock be pro-vided to require containment spray prior to starting the recombiners because of the large quantities of heat input to the containment. Incorrect implementation of this interlock could result in inability to operate the recombiners without containment spray.

II. Resolution 1.GAI The Perry facility does not incorporate such an interlock in the design.

III. Schedulo Based on the above response, this item is considered closed for Perry with this submittal.

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Action Plan 39 - Plant Specific I. Issues Addressed 6.4 For the containment air monitoring system furnished by General Electric, the analyzers are not capable of measuring hydrogen concentration at volumetric steam concentrations above 60%. Effective measurement is precluded by condensa-tion of steam in the equipment.

II. Resolution 1.GAI The hydrogen analyzers provided in the Perry design have been tested for acceptability with 100% steam in the sample and are not supplied by General Electric.

III. Schedule Based on the above response, this issue is considered closed for Perry with this submittal.

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Action Plan 40 - Generic I. Issue Addressed 7.3 The analysis assumes that the containment airspace is in thermal equilibrium with the suppression pool. In the short-term, this is non-conservative for Mark III due to adiabatic compression effects and finite time required for heat and mass to be transferred between the pool and con-tainment volumes.

II. Resolution 1.GE "The Mark III containment pressure is limited by long-term pool heatup, where the assumption of temperature equilibrium is very conservative. The effect of non-equilibrium on short-term pressures in the containment has been evaluated, and for design basis accident class breaks non-equilibrium effects increase the containment pressure by about 1/2 psi (about 10%) for the interval between 2 and 20 seconds into the transient. These secondary effects are easily overcome by other identified conservatisms in the method. The design is limited by long-term response where the thermal equili-brium assumption is conservative."

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal. This response was submitted by Grand Gulf in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference

  1. AECM-82/237, dated May 28, 1982, and accepted by the NRC.

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Action Plan 41 - Plant Specific I. Issues Addressed

12. Suppression Pool Makeup LOCA Seal In The upper pool dumps into the suppression pool automatically following a LOCA signal with a thirty minute delay timer. If the signal which starts the timer disappears on the solid state logic plants, the timer resets to zero preventing upper pool dump.

l II. Program for Resolution 1.GAI The criteria for upper pool dump following initiation of a LOCA signal will be clarified.

2.GAI The present Perry relay logic design resets the timer if the LOCA signal is removed. The logic for the suppression pool makeup system will be revised if required per Item 1.

III. Schedule Items land 2 are complete and included in this submittal.

IV. Final Program Results Item 1 The criteria for upper pool dump following initiation of a LOCA signal has been clarified such that it shall include seal in circuitry. This is necessary to assure compliance with the IEEE-279 requirement that protective system action, once initiated, shall go  :

to completion unless terminated by deliberate operator action.

Item 2 A design change has been initiated to seal in the thirty-minute timer. This will ensure upper pool dump thirty minutes following i

receipt of a LOCA signal unless the operator intervenes, i l I

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Action Plan 42 - Plant Specific I. Issue Addressed

13. Ninety Second Spray Delay The "B" loop of the containment sprays includes a 90 second timer to prevent simultaneous initiation of the redundant containment sprays. Because of instrument drift in the sensing instrumentation and the timers, GE estimates that there is a 1 in 8 chance that the sprays will' actuate simul-toneously. Simultaneous actuation could produce negative pressure transients in the containment and aggravate temp-erature stratification in the suppression pool.

II. Resolution 1.GAI The analyses provided in Section 6.2.1.1.4.2 of the Perry FSAR are based on simultaneous initiation of both spray loops.

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal.

1 Action Plan 43 - Plant Specific I. Issues Addressed

15. Secondary Containment Vacuum Breaker Plenum Response The STRIDE plants had vacuum breakers between the containment and the secondary containment. With sufficiently high flows through the vacuum breakers to containment, vacuum could be created in the secondary containment.

II. Resolution 1.GAI This item is not applicable to Perry because of the vacuum breaker system design which utilizes ouside air not secondary containment air.

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal.

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Action Plan 44 - Plant Specific I. Issue' Addressed

18. Effects of Insulation Debris .

18.1 Failures of reflective insulation in the drywell may lead to blockage of the gratings above the weir annulus. This may increase the pressure required in the drywell to clear the first row of drywell vents and perturb the existing load definitions.

18.2 Insulation debris may be transported through the vents in the drywell wall into the suppression pool. This debris could then cause blockage of the suction strainers.

II. Resolution 1.GAI The insulation used at Perry is a stainless steel clad fiberglass blanket. It is specifically designed to result in minimal loss under DBA conditions and has been tested to remain porous even when piled in several layers. A topical report was filed with the NRC regarding this insulation. The staff has accepted this report, " Nuclear Containment Insulation System", OCF-1, in a letter dated December 8, 1978.

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal.

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Action Plan 45 - Generic I. Issue Addressed 6.1 General Electric-had recommended that the drywell purga compressors and the hydrogen recombiners be activated if the reactor vessel water level drops to within one foot of the top of active fuel. This requirement was not incorporated in the emergency procedure guidelines.

II. Resolution 1.CEI The Emergency Procedure Guideline will require the operator to initiate operation of the combustible gas control system on high hydrogen concentration alarm from the hydrogen-analyzers. The drywell purge compressors and the hydrogen recombiners are not required until hydrogen has been generated.

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal.

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Action Plan 46 - Generic I. Issue Addressed

17. Emergency Procedure Guidelines The EPGs contain a curve which specifies limitations on suppression pool level and reactor pressure vessel pressure.

The curve presently does not adequately account for upper pool dump. At present, the operator would be required to initiate automatic depressurization when the only action required is the opening of one additional SRV.

II. Resolution This item is considered to be resolved since it is not a safety concern. Vessel depressurization does not adversely effect any assumptions made with respect to containment response. The effect of increased suppression pool water level (up to approximately 5 feet) due to inadvertent dump could be up to 0.1 psi increase in the pool boundary loads and submerged structure loads. This assess-ment is based upon the use of the SRV load definition methodology contained in Appendix 3B of the Perry FSAR.

The effect of increased suppression pool water level could be up to a 5% increase in the maximum operating pressure in the SRV discharge piping. The pressure stress is not one of the controlling loads for the piping design; valve dischargo dynamic loads and structural response loads are the controlling loads. A 5% increase in pressure j is, therefore, inconsequential.

III. Schedule Based on the above response, this item is considered closed for l

Perry with this submittal. This response was submitted by Grand Gulf in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference-#AECM-82/237, dated May 28, 1982, and accepted by the NRC.

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Action Plan 47 - Plant Specific I. Issue Addressed 1.7 GE suggests that at least 1,500 square feet of open arec should be maintained in the HCU floor. In order to avoid excessive pressure differentials, at least 1,500 f t* of opening should be maintained at each containment elevation.

II. Resolution 1.G The Perry design provides open areas on all floors above the HCU floor greater than the open area at the HCU floor (1,900 ft') which assures adequate venting.

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal.

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Action Plan 48 - Plant Specific I. Issue Addressed 5.7 After upper pool dump, the level of the pool will be 6 feet higher, and drywell-to-containment differential pressure will be greater than 3 psi. The drywell H2 purge compressor head is nominally 6 psid. The concern is that after an upper pool dump, the purge compressor head may not be sufficient to depress the weir annulus enough to clear the upper vents. In such a case, H2mixing w uld not be achieved.

II. Program for Resolution 1.GAI It will be verified that the discharge pressure of the H 2

purge compressors is sufficient to clear the upper vents following an upper pool dump.

III. Schedule Item I is complete and included in this submittal.

IV. Final Program Results Item i It has been determined that in the event of an upper pool dump and when the suppression pool is at its High Water Level (HWL) the maximum pressure differential between the containment and the drywell, without suppressing the weir area water below the top of the upper row of vents, would be 5.80 psid. Under this situation and any defined inlet conditions (temperature, pressure, and relative humidity) the Drywell Mixing Subsystem Compressor will be abic to suppress the weir area water below the top of the upper row of vents.

For example, the drywell mixing subsystem compressors are designed for a capacity of 500 scfm and a compression ratio of 1.48 when the containment (inlet conditions) is at 14.69 psia, temperature at 90 F, and a relative humidity of 50%. Assuming the 5.80 psid would exist between the containment and drywell, the compressor capacity would decrease to approximately 350 to 375 scfm with an approximate pressure ratio of 1.53. The results indicate that the drywell mixing subsystem compressors, under worst conditions, would pressurize the drywell volume and clear the top of the upper row vents and induce mixing between the drywell and containment atmosphere.

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Action Plan 49 - Plant Specific I. Issues Addressed

21. Containment Makeup Air for Backup Purge Regulation Guide 1.7 requires a backup purge 11 2 rem val capability. This backup purge for Mark III is via the drywell purge line which discharges to the shield annulus which in turn is exhausted through the standby gas treatment system (SGTS). The containment air is blown into the drywell via the drywell purge compressor to provide a positive purge.

The compressors draw from the containment, however, without hydrogen clean air makeup to the containment, no reduction in containment hydrogen concentration occurs. It is necessary to assure that the shield annulus volume contains a hydrogen lean mixture of air tc be admitted to the containment via containment vacuum breakers.

II. Resolution This issue is not applicable to Perry since outside air is provided to the containment via vacuum breakers. The Containment Vacuum Relief System fluid system diagram is shown in FSAR Figure 6.2-60.

III. Schedule Based on the above response, this item is considered closed for Perry wit.h this submittal.

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Action Plan 50 - Generic i I. Issue Addressed 5.2 Under technical specification limits, bypass leakage corres-ponding to A K = 0.1 ft.* constitute acceptable operating conditions. Smaller-than-IBA-sized breaks can maintain break flow into the drywell for long time periods, however, because the RPV would be depressurized over a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period. Given, for example, an SBA with A K = 0.1, projected time period for containment pressure to reach 15 psig is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. In the latter 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the depressurization the containment would presumably experience ever-increasing overpressurization.

II. Resolution The existing containment cooling systems will control containment pressure and temperature during early increases. If the containment pressure reaches 9 psig, the containment sprays automatically initiate. The operator can manually initiate containment sprays if the containment temperature rises faster than the containment pressure. Finally, the operator can initiate rapid reactor depres-surization if containment temperatures and pressures continue to rise.

III. Schedule Based on the above response, this item is considered closed for Perry with this submittal. This response was submitted by Grand Gulf in a letter from L. F. Dale, MP&L, to H. R. Denton, NRC, reference #AECM-82/237, dated May 28, 1982.

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PERRY NUCLEAR POWER PLANT ATTACHMF.NT 2 HUMPHREY ISSUES - ACTION PLAN

SUMMARY

Responsible Humphrey Issue Action Plan No. Organization No. Schedule Status As of 1/17/83

1. LOCAL ENCROACHMENTS 1.1, 1.2, 1.4 5/29/83 1.1 GE Complete (

l.2 GE Complete 1.3 GE Complete 1.4 CE Complete 1.5 GE Complete 1.6A GE Plant Specific 1.6 GE Plant Specific

2. SUBMERGED STRUCTURED LOADS 1.3 5/29/83 2.1 GE Ongoing / Plant Specific 2.2 GAI Ongoing / Plant Specific 2.3 GAI Ongoing / Plant specific i 3. PIPING IMPACT LOADS 1.5 5/29/83 y 3.1 GAI Outgoing / Plant Specific

' 4 HORIZONTAL LOADING 1.6 2/28/83 4.lA GE Complete 4.1 GE Complete 4.2 GAI Ongoing / Plant Specific

5. SRVDL SLEEVE-LOADINGS 2.1, 2.2, 2.3 5.1 GE Complete 5.2 GE Complete 5.3 GAI Complete 5.4 GAI Complete 5.5 GAI Complete 5.6 CAI Complete
6. RHR DISCHARGE LINE LOADS 3.1, 3.3, 3.7 2/28/83 6.1 GAI Oagoing/ Plant Specific 6.2 GAI Complete 6.3 GAI Complete 6.4 GAI Complete

Responsible Humphrey Issun Action Plan No. Organization No. Schedule Statua An Of 1/17/83 6.5 GAI Complete 4

6.6 CAI Complete 6.7 GAI Complete

7. RHR SUBMERGENCE 3.2 7.1 GE Complete ( }
8. RHR (SECOND POP) 3.4, 3.5 2/28/83 8.1 CAI Complete 8.2 GAI Complete 8.3 GAI Ongoing / Plant Specific 8.4 GAI Ongoing / Plant Specific 8.5 GAI Ongoing / Plant Specific
9. SUPPRESSION POOL TEMP. STRAT. 3.6 9.1 GE Comp 1ete 9.lA GE Complete 9.2 GE Complete
10. DBA-BULK POOL TEMP. 4.1 10.1 GE Complete
11. CONTAINMENT ANALYSIS P/T 4.2, 9.1 11.1 GE Complete 11.2 GE Complete 11.3 GE Complete 1.2 SUPPRESSION POOL MIXING 4.3 12.1 GE Comp 1ete 12.2 GE Complete 12.3 GE Complete } ^
13. CONTAINMENT ANALYSIS METHODS 4.4, 7.1 13.1 GE Complete 13.2 GE Complete
14. SUPPRESSION POOL STRAT. (CHUGGING) 4.5 14.1 GE Complete ( }

Responsible Humphrey Issue Action Plan No. Organization No. Schedule Status A1 Of 1/17/83

15. INITIAL SUPPRESSION POOL TEMP. 4.6 15.1 CAI Complete 15.2 GAI Complete
16. SUPPRESSION POOL COOLING 4.7, 4.10 16.1 GAI Complete ( }
17. RHR-CONT. SPRAY 4.8 2/28/83 17.1 GE Ongoing / Generic 17.2 GE Ongoing / Generic
18. SPRAYS - CYCLICAL DUTY 4.9, 5.3 2/28/83 18.1 GE Ongoing / Generic 18.1A GE Ongoing / Generic
19. DRYWELL BYPASS LEAKAGE 5.1, 5.6, 9.2 2/28/83 19.1 GE Ongoing / Generic 19.2 GE Ongoing / Generic e 19.3 GE Ongoing / Generic w
20. H2 - POCKETING 5.4 20.1 GAI Complete
21. EQUIPMENT ENV. COND. 5.5 21.1 GAI Complete
22. HIGH TEMP. IN DRYWELL 5.8 22.1 GE Complete 22.2 CAI Complete
23. H2 RECOMBINERS 6.3, 6.5 23.1 GAI Complete
24. GE CONT. P/T-EQUIP. QUAL. 7.2 24.1 GE Complete
25. TECH. SPECS./ ANALYSIS VALUES GE 8.1 2/28/83 25.1 GE Complete 25.2 GE Ongoing / Generic i

Responsible Humphrcy Issus Action Plan No. Organization No. Schedulg Statu,A3 Of 1/17/83 j 25.3 GE Complete 25.4 CEI . Ongoing / Plant Specific

26. DRYWELL-PRESSURE NORMAL 8.2, 8.3 26.1 CEI Complete
27. CONTAINMENT NEG. PRESSURE 8.4 27.1 GAI Complete 27.2 GAI Complete 27.3 GAI Complete
28. SBA & STUCK OPEN SRVs 9. 3 28.1 GAI Complete
29. WEIR OVERFLOW - U.P. DUMP 10.1 29.1 CAI Complete 29,2 GAI Complete i 30. INTERFACE REQUIREMENT (A-42) GAI 10.2 Complete
31. WEIR / SUPPRESSION POOL LEVEL DIFF. 11.0

' 31.IA GE Complete 31.2 GAI Complete 31.3 GE Complete

32. LPCI-CONT. SPRAY BACK FLOW 14.0 32.1 GE Complete
33. SUPPRESSION POOL TEMP. SENSORS 16.0 33.1 CEI Complete
34. CHUGGING LOADS - U.P. DUMP 19.1 34.1 GE Complete 34.2 GE Complete 34.3 GE Complete '
35. ENCROACHMENTS-CHUGGING LOADS 19.2 35.1 GE Complete 35.2 GE Complete

Responsible Humphrey Issue Action Plan No. Organization No. Schedule Statua An Of 1/17/83

36. WEIR SWELL 21.0 36.1 GAI Complete
37. EPGs 22.0 37.1 CEI Complete ( }
38. CONTAINMENT SPRAY /RECOMBINERS INTERLOCK 6.2 38.1 CAI Complete ( }
39. CONTAINMENT AIR MONITORING SYS. 6.4 39.1 GAI Complete

, 40. CONTAINMENT ANALYSIS EQUIL. 7.3 l

40.1 GAI Complete (

41. SUPPRESSION POOL MAKEUP-LOCA SEAL IN 12.0 41.1 GAI Complete 41.2 CAI Complete w

' 42. 90-SECOND SPRAY DELAY 13.0 42.1 CAI Complete ( }

43. VACUUM BREAKER - CONT. 15.0 43.1 GAI Complete
44. INSULATION DEBRIS 18.0, 18.1, 18.2 44.1 CAI Complete 44.2 GAI Complete (
45. PURGE COMP.-H2 RECOMBINERS TECH. SPEC. 6.1 45.1 CEI Complete ( }
46. EPG 17.0 46.1 CEI Complete ( }
47. MCU OPEN AREA 1.7 47.1 GAI Complete ( }

Responsible Humphrey Issua Action Plan No. Organization No. Schedule Status An Of 1/17/83

48. H2 COMPRESSORS 5.7 48.1 GAI Complete  !

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49. CONT. MAKEUP AIR FOR BACKUP PURGE 21.0 49.1 CAI Complete ( )

i 50. DRYWELL BYPASS LEAKAGE - SBA 5.2 50.1 GE Complete O) 1 l .

1 KEY: GE - CENERAL ELECTRIC CEI - CLEVELAND ELECTRIC ILLUMINATING ,

GAI - GILBERT ASSOCIATES, INC.

1) Letter from D. R. Davidson, CEI, to A. Schwencer, NRC, " Perry Nuclear Power Pltnt, SER Outstandiing Issue No. 8, Mark III Containment System Issues," dated September 9,1982.

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