ML20128K065

Submits Results of Review of Info in ,Clarifying &/Or Modifying Extent of Facility Conformance to Reg Guides 1.52,1.140 & 1.143 & Ser.Exceptions to Airflow Capacity Testing & to air-aerosol Mixing Testing Unacceptable

ML20128K065
Person / Time
Site:	Perry
Issue date:	05/20/1985
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8505310073
Download: ML20128K065 (3)

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MAY 2 01935 Docket Nos.: 50-440 and 50-441 Mr. Murray R. Edelman, Vice President Nuclear Operations Group The Cleveland Electric-Illuminating Company P. O. Box 5000 Cleveland, Ohio 4d101

Subject:

Perry Nuclear Power Plant (Units 1 and 2) Conformance with 8 Regulatory Guides (FSAR Table 1.8-1 and 1.8-2)

This letter contains the interim results of the staff's review of the infor-mation presented in your letter dated April 2,1985, clarifying and/or modifying the extent to which Perry conforms to Regulatory Guides. Specifically com-mented on below are the staff's comments relative to Regulatory Guide 1.52, 1.140 and 1.143 which, unless satisfactorily responded to by your staff, could alter the conclusions pertaining to these regulatory guides in Section 11 of the SER and Supplements amending Section 11 of the SER. Changes to the specific system changes related in FSAR Amendment 18, are still under review by the staff and will be commented on separately, as will the staff's comments on Perry's conformance with other regulatory guides clarified in your April 2,1985 letter.

It is accordingly requested that CEI respond on a priority basis to the following staff comments.

1. While the applicant claims to have conformed to Regulatory Guides

'1.52 and 1.140, in reality inspections have shown that silicone sealants- have been utilized in both ESF and non-ESF systems. This is contrary to regulatory position C.5.c of these guides and may alter the staff's conclusion stated in the SER.

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Mr. Murray R. Edelman, Vice President Nuclear 0porations Group The Cleveland Electric Illuminating Company P. O. Box.5000-Cleveland, Ohio 44101 cc: -Jay Silberg, Esq.- Mr. Larry 0. Beck Shaw, Pittman,:& Trowbridge . The Cleveland Electric

.1800 M Street, N. W. Illuminating Company Washington, D. C. 20006 P. O. Box 97 E-210 Perry, Ohio 44081 Donald H. Hauser, Esq.

The Cleveland Electric-Illuminating Company

. P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office U. S. Nuclear Regulatory Commission Parmly at Center Road Perry, Ohio 44081 Regional Administrator

, U. S. NRC, Region III 799 Roosevelt-Road Glen Ellyn, Illinois' 60137

. Donald T. Ezzone, Esq.

Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 Ms. Sue Hiett OCRE Interim Representative 8275 Munson Mentor, Ohio 44060 Terry J. Lodge, Esq.

618 N. Michigan Street Suite 105 Toledo, Ohio 43624 John G. Cardinal, E:q.

Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047

MAY 2 01985 g Mr. Murray R. Edelman l

2. The Perry FSAR Pages 11.3-2, 11.3-14 and Table 11.3-6 indicated I that materials utilized in the gaseous radwaste system were ASME, l Section II materials with Table I of Regulatory guide 1.143. The l April 2,1985 letter states that these materials now meet ASTM standards. This cannot be considered appropriate for pressure vessels, atmospheric tanks or heat exchangers without further explanation. This may alter the staff's conclusion expressed in the SER.

3. BTP ETSB-11.3 does not describe how a solid radwaste system is to be fabricated. Perry has a UNI system which has never worked at any plant. All installations where this system has been proposed have resorted to other solidification means, usually portable systems.

What is Perry doing? The conclusions in the SER may not be appropriate in view of this change.

4. The SER input for Section 11.2, Liquid Radwaste Treatment System, was based upon the design and construction of all components satisfying or exceeding the intent of Regulatory Guide 1.143. This was noted on Pg. 11-4 of the SER. In the applicant's recent letter, they indicated that these component's materials conformed to ASTM Standards and were constructed to high industry standards. Without further detail the staff would have to conclude that this change does not meet the criteria of the above guide and impact negatively on the conclusion stated in the SER.

5. The exceptions to airflow capacity testing and to air-aerosol mixing testing are not acceptable. These tests should be performed in accord-ance with ANSI N510 1980 (Regulatory guide 1.52). Otherwise the con-clusions expressed in the SER may be negated.

This matter will be considered an SER Confirmatory Issue in the next SER Supple-ment which must be satisfactorily resolved prior to Unit I licensing. If your staff wishes to discuss the above comments with the staff prior to responding, please have them contact the Perry Project Manager, John Stefano, in order that arrangements can be scheduled.

Sincerely, B. J. Youngblood, Chief Licensing Branch No.1 Division of Licensing cc: See next page DISTRIBUTION:

Docket File JStefano CWillis NRCPDR OELD JHayes LPDR ACRS (16) JGrobe NSIC EJordan RXnop, Region III

{.B#1:DL -LB#1:DL PRC System JPartlow WGammfil JStefano:kab " J JYoungblood LB#1 R/F MRushbrook BGrimes 905/3 0 /85 vr- 05/20 /85