ML20098D974
| ML20098D974 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/14/1992 |
| From: | Lyster M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20098D962 | List: |
| References | |
| GL-88-01, GL-88-1, NUDOCS 9206010151 | |
| Download: ML20098D974 (5) | |
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G CENTERIOR ENERGY PERRY NUCLEAR POWER PLANT i i M ore u.
p Michael D. Lyster E RY. OHIO 4 081 (210 2 n r r April 14, 1992 PY-CEI/NRR-1473 L U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D.C.
20555 Perry Nuclear Power Plant Docket No. 50-440 St k;ule for Response to NRC SER on Generic Letter 88-01 "NRC Position on IGSCC in BVR Austenitic Stainless Steel Piping" Gentlemen:
By letter dated February 10, 1992, the NRC staff responded to our letters of July 29, 1988 (PY-CEI/NRR-0894L), June 15, 1989 (PY-CEI/NRR-1027L), and July 31, 1989 (PY-CEI/NRR-1044L). The NRC's Safety Evaluation and its attached Technical Evaluation Report (TER) reviewed the Cleveland Electric Illuminating Company responses to each of the NRC Staff Positions expressed in Generic Letter 88-01 entitled "NRC Position on ICSCC In BVR Austenitic Stainless Steel Piping", its Attachment A, and the associated NUREG-0313 Rev. 2 " Technical
' Report on Material Selection and Processing Guidelines For BVR Coolant Pressure Boundary Piping".
The NRC letter accepted the majority of the CEI responses to the Generic Letter 88-01 Positions, but took exception to three of the CEI responses.
Specifically, the Staff disagreed with the following positions:
1.
not to amend the Perry Technical Specifications to include a statement on Inservice Inspection, as specified in the Generic Letter 2.
not to acecpt the operability of leakage monitoring instruments in accordance with the revised staff position 3.
not to amend the Technical Specifications to initiate a plant shutdown in the event of a 2 gpm increase in unidentified reactor coolant system leakage vithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The NRC's February 10, 1992 letter requested that proposed changes to the Perry Nuclear Power Plant (PNPP) Technical Specifications that conform with the Generic Letter 88-01 Positions be submitted.
It also requested that a schedule for our response to the NRC letter be provided. This response letter provides tems, and additional brief schedules for addressing each of the above i
discussions of our objections to certai.n items.
It is requested that NRC management take note of the issues raised by the Staff and of those raised by CEI in this letter and in future meetings and correspondence on this Generic Letter. CEI belle.es that the Staff positions w icccw r,
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USNRC April 14, 1992 PY-CEI/NRR-1473 L taken on the three issues identified in the February 10, 1992 letter are either not consistent with the Commission's Interim Policy Statement on Technical Specification Improvement, or may involve backfits for PNPP pursuant to 10 CFR 50.109, or provide further examples in support of industry comments made during the Regulatory Impact Survey regarding NRC imposition of " requirements" through the use of Generic Letters.
As noted belov, a copy of this letter is being provided to Mr. Samuel J. Chilk, Secretary of the Commission, in order to bring these concerns to the attention of the NRC Commissioners.
As noted above, CEI expects to address each issue in more detail in future meetings and supplemental correspondence; the purpose of this letter is to clarify our objections and propose schedules for resolution of the issues.
Addition of a Statement to Specification 4.0.5 The NRC Staff's first exception was to the CEI proposal to make a commitment to the Generic Letter Pcsitions on Inspection Schedules, Methods and Personnel, and Sample Expansion. rather than adding a statement to Technical Specification 4.0.5 to this effect. CEI believes that (1) adding a commitment such as this to the Technical Specifications is inconsistent with the Commission's Interim Policy Statement on Technical Specification Improvements; (2) the NRC interpretation of Generic Letter 88-01 as requiring each licensee to change their Technical Specifications to include a commitment statement (see TER Sections 3.1.1 and 3.1.?) is inconsistent with the positions the Staff has espoused in response to indurtrv concerns expressed in the Regulatory Impact Survey; and (3) the addition d this change is purely administrative and would I
not result in any improvement in plant safety above that provided by our alternative proposal to incorporate such a statement into the PNPP Inservice Examination Program. Further details on CEI's position on this overregulation irsue vill be provid?d in subsequent correspondence to the Commission.
In addition to the above considerations, the standard phraseology for a Technical Specification change provided by the NRC-Staff in Generic Letter 88-01 could not be utilized in PNPP's. case, since CEI took exception to two of
- the three NRC Positions (Inspection Schedules, and Methods and Personnel), and our exceptions were approved by the NRC in their February 10, 1992 letter.
A simple commitment to th* NRC Positions vould not be accurate.
Such wording
- would be similar to the following:
The Inservice Inspection Program for. piping identified in NRC Generic Letter 88-01 shall be performed in accordance with the NRC Staff Positions in the Generic Letter on Inspection Schedules, Methods and Personnel, and Sample Expansion, as modified by CEI letter dated July 31, a
1989 (PY-CEI/NRR-1044L) and approved by the staff by letter dated February 10, 1992.
Again, this vould be purely an administrative change to the Technical Spacifications which would not result in any improvement in plant operational safety, therefore CEI does not plan to submit such a Technical Specification m
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USNRC April 14, 1992 PY-CEI/NRR-1473 L change request. To date, PNPP has been performing activities in accordance with our previous Generic Letter 88-01 commitments on Inspection Schedules, Methods and Personnel, and Sample Expansion. However, CEI vill commit to the addition of such a " motherhood" statement to the Inservice Examination Program (ISEP). The schedule for addition of the above statement into the PNPP ISEP is to have it incorporated by December 31, 1992, as part of a revision to the program that vill be prepared to incorporate lessons learned from Refueling Outage 3.
The above commitment, along with previous commitments, ensures that sppropricte ISI examinations vill be performed, and responses to examination findit.gs vill be taken.
Leakage Monitoring upon Loss of a Dryvell Sump The NRC's second exception was to the CEI position that the current-licensing basis for PNPP vas acceptable with respect to the Technical Specification required Action to be taken upon inoperability of the dryvell sumps. The NRC Staff originally proposed (in Generic Letter 88-01) an allowable outage time of only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a plant shutdown must begin. vith no provisions for alternative methods of leak detection during any longer allovable-outage time.
CEI stated that'PNPP utilized the dryvell cooler condensate flow rate monitoring system as an alternative leafage ~ detection method capable of detecting a 1 gpm leak uithin I hour, to be used for an allovable outage time of 30 days, and that.this was part of the NRC approved licensing basis for the plant. The NRC's Jafety Evaluation and attached TER both state that the reason for NRC's exception to CEI's proposal is that the upper dryvell cooler condensate flow rate monitoring system does not provide sufficient accuracy in quantifying leakage (i.e. a 1 gpm within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. capability is not acceptable).
In their Safety Evaluation, the NRC therefore directed that another method should be established (and demonstrated) that vould rore ac:urately measure leakage, such as by manually pumping the sump or measuring differenirs in sump level, in order'for a 30-day allovable outage time for the sumps to be acceptable.
The'rention of the "1 gpm vithin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />" capability for the dryvell cooler condensate flow rate monitoring system vaa included in the CEI letter since this is the only known published NRC acceptance criteria for leakage detection (see Regulatory Guide 1.45).
If_the Staff has developed more restrictive
-criteria, they have not transmitted these " requirements" to CEI specifically or the industry in general. In fact,-the PNPP FSAR (and subsequently the USAR) is very clear as to which leakage detection systems meet the Regulatory Guide 1.45 criteria. This information on leakage detection accuracy was reviewed and approved-by the NRC staff as part of the PNPP licensing process, as was the 30-day allovable outage time for dryvell sump inoperability that was included in the original PNPP Technical Specifications. The 30-day allovable outage time for the sumps, while depending on the dryvell cooler condensate flow rate monitoring system, was reaffirmed by the NRC in Amendment 30 to the PNPP Operating License. In actuality, the accuracy of the dryvell cooler condensate flow rate monitoring system can be shown to be significantly greater than just
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e USNRC April 14, 1992 PY-CEI/NRR-1473 L "l-gpm within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." Ve maintain our position that this monitoring technigte is acceptable, and imposing the sump pumpout as the only acceptable option constitutes a backfit as defined in 10CFR50.109(a)(1).
While CEI sees merit in the capability to establish a 30-day allovable outage time based upon manual' sump pu.apouts every shif t as proposed by the NRC, it is not clear that the NRC's backfit that vould remove the current Action from the Technical Specifications is justified.
Ve do not agree that he revised leakage monitoring proposal represents a substantial iacrease in the overall ptotection of public health or safety..In future correspondence and meetings, further information on the dryvell cooler condensate flov rate monitoring system vill be provided, and discussicns vill be held with the Staff to obtain further details on their position. CEI believes that these discussions vill lead to a resolution acceptable to CEI and-NRC.
In the interim, PNPP vill continue to comply with our current Technical Specification for this particular issue.
It is proposed that the tentative schedule for resolution of this issue be r - (1) CEI and NRC preparation for a metting to be held following completion of the busy spring outage season and after plant startup activities (proposed meeting date - veek of July 13, 1992); (2) follow up correspondence and information exchanges leading to issue resolution by the end of October 1992; (3) any interim procedural controls that are determined to be necessary as a result of the resolution being made effective within ninety days of such resolution, and (4)-Technical Specification changes that are detirmined to be-necessary as a result of the resolution to be submitted to NRC vithin two full calendar ouarters following the resciation date.
Addition of the "2 gpm rate increase over any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period" limit The NRC's third exception was to the CEI pcsition that if stress improvement was applied to the 1GSCC susceptible velds, that s' requirement would not be incorporated into the Technical Specifications to-direct-a plant shutdown for inspection and corrective actions when, within any period of'24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, any leakage detection system indicates an increase in rate of-unidentified leakage in excess of 2 gpm. The'NRC' Safety Evaluation and TER stated that although stress improvement is still being considered for PNPP, that the 2 gpm unidentified leakage rate increase limit is intended to apply to all BVR plants regardless of the classificatior, of the velds.
CEI again objects to the wording in the TER that states that the 2 gpm limit is a " requirement" of the Generic Letter (see TER Section 3.2.6).
Ve would like
' to reiterate the previousi; established industry position that Generic Letters cannot be used to unilaterally _ impose-new requirements on licenrees.
CEI does recognize that BVR plants with IGSCC susceptible-velds have committed to similar limits in the past, and in~ fact, since the second refueli:.g outage when ISI examinations first identified indications in PNPP's IGSCC susceptible velds, PNPP has actually utilized the "2 gpm rate-increase within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" as a guideline, even though it was not incorporated into plant procedures (for
- example, reference the April 1,1991 plant shutdown). It should be noted that-work is ongoing through the E'JR Ovners Grcup to justify a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period m
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vb USNRC April 14, 1992 PY-CEI/NRR-1473 L r.ther than the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period as the vindov vhich must be exa:Ined for the 2 gpm rate increase.
A limit of this type on unidentified leakage rate increases appears to be an appropriate restriction. therefore PNFP commits to.such a limit.
PNPP vill use a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period as the vindov to be examined, at least until the BVR Ovners Group work ic reviewed and approved. This shutdown requirement vill be added to plant procedures prior to restart from the current refueling outage, with subsequent Technical Cpecification changes being submitted to the NRC within two full calendar quarters following final resolution between the NRC and the Owners Group as to the appropriate time period to be used (either 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). During the interim period until Technical Specification changes are submitted, the above commitment vill ensure compliance.
The vording of the procedure changes vill be provided for NRC information prior to restart from the refueling outage. As noted in previous letters, as a minimum, this requirement vill have to allow for re-establishing background rates of-leakage during plant starturs.
It also vill include provisions similar to those in the Standard Technical Specifications that provide a shoct time period (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> af ter a 2 gpm increase within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been experienced) to identify the source of the leakage increase as not being from one of the IGSCC susceptible velds (this time period is also under discussion with the NRC through the BVR Ovners Group).
The further correspondence and discussion to be held with the Staff over the next several months should serve to resolve the above is ies.
If there are any further questions, please feel free to call.
Sincere {,
&1 LJ t' hael D. Lyster MDL:BSF:ss cc:
NRC Project Manager NRC-Resident Inspector Office L
NRC Region III Secretary of the Commission NUMARC NUBARG l
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