ML20107C938

Forwards Applicant Answers to Ohio Citizens for Responsible Energy 850211 Response to Applicant Motion for Summary Disposition of Issue 15 Due to Inconsistencies W/ Interrogatory Answers.Related Correspondence

ML20107C938
Person / Time
Site:	Perry
Issue date:	02/19/1985
From:	Silberg J SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Bright G, Gleason J, Kline J Atomic Safety and Licensing Board Panel
References
CON-#185-670 OL, NUDOCS 8502220150
Download: ML20107C938 (7)

Text

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SHAW, PITTMAN, PoTTs;& TRdk$fbGE A PARTNERSMip Or PROFESSIONAL CORpORAfiONS 1800 M STRE ET. N. W. .

WASHINGTON. 3. C. 200 5 FEB 21 A10:09 ret = i R 12O28 822-8099 & 822-ti99 CFFICE OF SECRETtr .....e I*,'A,u S .S ,

February 19, 198500CKETING & SEPvtC: cA.<c.S A.u.-

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.J AY E. SILBERG, P.C. (202i saa-toes

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James P. Gleason, Chairman Atomic Safety and Licensing Board 513'Gilmoure Drive Silver Spring, Maryland 20901 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 The Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2)

Docket Nos. 50-440 and 50-441 O L Gentlemen:

OCRE's February 11, 1985 Response to Applicants' Motion for Summary Disposition of Issue 15 (at page 3) references two of Applicants answers (Nos. 9-44 and 9-46) to OCRE interrogatories. Because OCRE's characterization of these answers is inconsistent with the interrogatory answers themselves, there is enclosed for the Board's convenience a copy of the relevant answers.

Very truly yours, J

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ILBERG 80o.

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March 8, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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THE CLEVELAND ELECTRIC )

ILLUMINATING COMPANY, ET AL. ) Docket Nos. 50-440

) 50-441 (Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' ANSWERS TO OHIO ,

CITIZENS FOR RESPONSIBLE ENERGY INTERROGATORIES 9-1 THROUGH 9-25 AND 9-38 THROUGH 9-52 RELATING TO ISSUE NOS. 13 AND 15

, 4' Applicants for their answers to Ohio Citizens for

-Responsible Energy ("OCRE") Interrogatories #9-1 through #9-25 and #9-38 through-#9-52 from OCRE's Ninth Set of Interrogatories to Applicants, dated January 31, 1983, state as follows:

All documents supplied to OCRE.for inspection will be

. produced either at Perry Nuclear Power Plant ("PNPP"), for documents in the possession of The Cleveland Electric

' Illuminating company-("CEI"), or at the offices of Gilbert I

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. p The inservice inspection program for extracti 6n' steam

. piping will be consistent with the following principles.

Radiographic or ultrasonic test-tsIhniques will be used to

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c determine actual wal itikness of the piping. These numbers will be compared t6 the minimum wall requirements shown in

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Attachmen,t-3'to determine if repair or replacement is required.

f AlL-r'epairs will be done according to ANSI /ASME B31-1.

9-44. Describe in detail any plans, provisions, designs, criteria, standards, etc. which Applicants may have for preventing steam erosion and the effects thereof.

Response

Modifications were made in the Extraction Steam System (N36), High Pressure ,(N25) and Low Pressure (N26) Heater' Drains and Vents Systems, and Main, Reheat, Extraction and Miscel-laneous Drain System (N22) beginning in 1976. These modifica-tions were made primarily to enhance system cperational reliability.

(a) N25/N26 - High Pressure and Low Pressure Heater Drains and Vents. Level will be controlled in the high pressure and low pressure heaters by means of a level: control switch which will open a control valve in either a normal or alternate flow path. Downstream of this control valve, severe erosion can occur. This problem has'been identified throughout the industry. To minimize the effects of erosion, a criterion D

was established that no directional changes in piping would be acceptable between the valve and heater / condenser.

Because of physical limitations, this criterion could not always be followed. Where directional changes occur, 90*

elbows were replaced with tee's and target plates with telltales added. See Attachment 2 for details. The stainless steel target plate will act as a wear plate and can be readily removed if necessary. This design has been used very succes-sfully at CEI's fossil fuel plants and has minimized erosion problems in heater drain lines.

(b) N22 - Main, Reheat, Extraction and Miscellaneous Drain System. The erosion problems associated with this system are identical to those discussed in (a) above. That is, erosion may occur downstream of the drain control valve.

Because this piping is mostly small bore (two inches or less),

Applicants decided not to use the solution described in (a) above. Instead, it was decided to change the material downstream of the control valve to a more erosion-resistant material. The material specified was A335, grade Pil or P12, which contains 1-1-1/4% chromium - 1/2% molybdenum.

(c) N36 - Extraction Steam Piping. As explained in response to Interrogatory #9-48(c), infra, erosion can occur in steam piping whenever high steam velocity or low steam quality -

exists. A review of the extraction steam piping system was undertaken by Applicants in 1977. Potential erosion problems-were identified in some of the extraction piping.

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r The piping for which potential problems were identified was replaced in Unit 2 with a more erosion-resistant material (A335, grade Pil or P12). Since it was not practical at that -

time to replace the Unit 1 extraction piping, it was decided to design an inservice inspection program to monitor piping elbow wall thickness in Unit 1 in order to enhance system reliabi-lity. See response to Interrogatory #9-43, supra.

In addition to the above changes, the seating surfaces of the MSIVs have been covered with more erosion-resistant materials.

9-45. Describe in detail any plans, provisions, programs N-ats. which Applicants may have for detecting and assessin steam- "osion or the effects thereof. ,

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Resconse: x Plans for detecting-and assessing, steam erosion in Unit 1 x ' y extraction steam piping are deNc 25ed in response to

~x Interrogatory #9-43, supr . Plans fod~" Type C" leak testing of the MSIVs are desc 'f'ed in response to Interrogatory #9-46, infra. In a ition, Applicants will have an. inservice. testing

's s, progra for all valves as required by ASME.Section XI. This"

• gram is still being developed.

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9-46. Describe in detail any plans, provisions, proce-dures, etc.-which Applicants may have.for mitigating steam erosion or the effects thereof. Include any procedures for the repair or' replacement of any affected components.

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Response

As stated in response to Interrogatory #9-43, supra, '

repair or replacement of Unit 1 extraction steam piping will be carried out as necessary to comply with the minimum wall ['

thicknesses set forth in Attachment 3. Note also that the ('

erosion allowances shown in Attachment 3 exceed the corre-sponding minimum wall thicknesses from 50% to 400%. The inspection program together with the conservatism in the erosion allowances will minimize steam erosion problems in the i extraction steam piping.

The PNPP main steam isolation valve ("MSIV") leakage control system also will mitigate the effects of steam erosion.

See FSAR S 6.7. This system is used to reduce the amount of radioactive material released to the environment. To accom-plish this, MSIV leakage is directed into the shield building annulus, which is serviced by the annulus exhaust gas treatment system. The MSIV leakage control system is designed to process 100 scfh total leakage per main steam line.

Main steam line leakage results from leakage past the MSIVs. Each line consists of an inboard isolation valve (B21F022), an outboard isolation-valve (B21F028), and a long term leakage control valve (N11F020).

To control valve leakage and to insure that the total main steam line leakage does not exceed the capacity of the MSIV leakage control system, the inboard MSIV and outboard MSIV will o

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be " Type C" leak tested according to the requirements of Appendix J to 10 C.F.R., Part 50. Leakage will not exceed 25 scfh per vcive. See FSAR Table 6.2-40, n.4. In addition, PNPP's Tech Specs will require that the leakage rate per valve be restored to less than 25 sefh prior to increasing reactor coolant system temperature abcVe 200* F. In the event these valves become a maintenance problem with regard to leakage, appropriate action (repair or replacement) will be taken.

To insure that the system capacity (100 scfh per line) is

.not exceeded, conservatism has been built into the MSIV leakage rate (25 scfh). Additional reliability is built into design due to the fact that leakage must pass through these isolation valves in series. Further, no credit has been taken in this analysis for the long term leakage control valve.

9-47. What is the vendor / manufacturer of the MSIV' o be used at PNPP?

Resconse:

Valve Manufacturer B21F022A,B,C,D At6 od and Morill Co.

B21F028A,B,C,D - Atwood and Morill Co.

NilF020A,B,C,D ,j/ Borg-Warner

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+5 s s-9-48. It is stated in IE Information Notice 82-22 that the Oconee license'e (Duke Power Co.) theorized that reduced power operatten and resultant lower quality steam contributed to accele oed steam erosion. .

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