ML20137L844
| ML20137L844 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/12/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0153, PY-CEI-OIE-153, NUDOCS 8601280107 | |
| Download: ML20137L844 (4) | |
Text
pmm THE CLEVELAND ELECTRIC ILLUMIN ATING COMP ANY P O. SOX 5000 - CLEVELAND OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG - 55 PUBLIC SOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN becember 12, 1985 S'
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{cE PY-CEI/01E-0153 L eLEAR C. E. Norelius, Director Division of Reactor Projects / Region III Of fice of Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 50-440/85082 Open Item Response
Dear Mr. Norelius:
This letter is to acknowledge receipt of Inspection Report 50-440/85082 attached to your letter dated December 1, 1985. This report identifies areas examined by Messrs. S. Stasek, J. McCormick-Barger, R. Evans, R. Larson and N. Spang during their inspection conducted November 18 through November 21, 1985 at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Open ' Item identified in the rep ort. We have completed the requested review as described in our attached response.
If there are additional questions, please do not hesitate to call.
Very truly yours, i9h
(
Murray R. Edelman Vice President Nuclear Group MRE:pic Att achment 9601280107 851212 PDR ADOCK 05000440 G
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1 C. E. Norelius December 12, 1985 PY-CEI/OIE-0153 L cc:
Mr. J. A. Grobe USNRC Site, SBB50 Mr. K. Connaughton USNBC Site, SBB50 U.S. Nuclear Regulatory Commission Document Control -Desk Washington, D.C.
20555 Mr. R. F. Warnick, Chief Reactor Projects Branch 1 Division of Reactor Projects U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois.
60137 Mr. John Stefano, NRR
\\
At t achment PY-CEI/0IE-0153 L Response to open Item 85082-01 Upon transmittal of the Final Draf t Perry Technical Specifications, the NRC requested that CEI certify that the document is consistent with the Final Safety Analysis Report (FSAR), the NRC Safety Evaluation Report (SER) and the as-built facility as a prerequisite for issuance of an operating license.
CEI had long been aware this would be required, and had begun implementing programs to ensure that the resources and processes used would provide a detailed and comprehensive basis for certification.
The Perry Technical Specifications were initially developed using the BWR/6 Standard Technical Specifications (NUREG-0123, proposed Rev. 4) and have been modified by Perry specific design values, FSAR information and preoperational test results. The Perry Technical Specifications have been updated to reflect modifications to plant design and are traceable to design documents. The Technical Specifications have undergone numerous extensive reviews by both CEI and the NRC, including two early draft reviews, proof and review phase and two final. draft reviews.
The Perry FSAR has undergone a verification review. This was performed by representatives of the utility, the architect / engineer, and the NSSS vendor.
The purpose of this review was to ensure the information in the FSAR was accurate and traceable to design documents. To ensure consistency between the FSAR and Technical Specifications, a detailed review of the Technical Specifi-cations against the FSAR and the SER was conducted in June 1985.
Each individual Limiting Condition for Operation (LCO), Action statement, surveillance requirement and bases section was reviewed against the FSAR descriptive material related to the specification under review. All apparent discrepancies were identified and reso".ved.
The SER and its supplements were also reviewed for descriptive materia i related to the specification under review. Prior to the review, seven items identified in the_ SER as requiring technical specifications were requested to be revised in letters dated February 11, February 12, February 13 and February 19, 1985. The results of the SER review showed consistency with the Safety Evaluation Report through Supplement No. 7.
The results of this total intensive review have been compiled in a matrix format to support our certification letter._ Through an on-going process of plant walkdown, the conduct of preoperational tests which-demonstrated the acceptance criteria of technical specifications, where practical, and our program of performing dry runs of the surveillance requirements of the technical specifications, we have' confirmed the technical
- specification are consistent with the as-built facility.
I
l t
Attachment PY-CEI/01E-0153 L During the week of November 19, 1985 a regional inspection team conducted an audit of the Perry Technical Specification. The audit team reviewed the Technical Specifications against the FSAR and the as-built plant for the High Pressure Core Spray, Emergency Closed Cooling Water, Reactor Recirculation, Low Pressure Core Spray, containment isolation and the Class IE AC power distribution systems. During the review, an apparent discrepancy was identi-fled.
The FSAR section (8.3.1.1.2.11.2) on the 4160v bus degraded voltage relay described the nominal setpoint as 95% of equipment rating voltage. The Technical Specification setpoint is 95% i 1%. The concern was that the tolerance could allow the setpoint to be non-conservative with respect to the FSAR. Actually, the FSAR described the nominal setpoint, not the analytical limit in this case, and generally does not describe tolerances. Based on analysis, the setpoint could actually be lowered to 94%.
In Amendment 22 the FSAR section has been clarified to reflect the lower bound setpoint as.94% to resolve the concern expressed during the audit. The inspection report identi-fied the same concern with respect to the undervoltage relay. Again, the FSAR value is not the analytical limit but is the nominal setpoint value. For consistency, the FSAR will be clarified to reflect the lower bound value for the undervoltage relay in the next amendment.
The inspection team suggested a representative sampling of FSAR values to ensure the equivalent Technical Specification values were consistent.
Although this was previously accomplished through the development of the FSAR/ Technical Specifications matrix described above, an additional sample review was performed. Most of the values throughout the FSAR are nominal values for system description purposes. The values chosen were representative of the key input variables in the Containment Response Analysis (Chapter 6),
the Accident Analyses (Chapter 15), and the Instrumentation and Controls Section (Chapter 7). It should be noted that the values from the analysis tables in Chapters 6 and 15 represent conservative analysis values, while Chapter 7 values are generally nominal values.
The additional comparison of the Technical Specifications values and respective FSAR parameters has been completed and the results further demonstrate that in all cases the Perry Technical Specifications are consistent with or conservative with respect to the Perry FSAR.