ML20196K418

Discusses Util 870918 Application for Amend to License NPF-58,eliminating MSIV Leakage Control Sys from Tech Spec Requirements for Surveillance & Operability.Amend Not Acceptable for Listed Reasons

ML20196K418
Person / Time
Site:	Perry
Issue date:	03/11/1988
From:	Perkins K Office of Nuclear Reactor Regulation
To:	Kaplin A CLEVELAND ELECTRIC ILLUMINATING CO.
References
GL-87-17, TAC-66080, TAC-66085, NUDOCS 8803150311
Download: ML20196K418 (6)

Text

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Docket No. 50-440 Distr' b at' ene N

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E ---- a T - Wanda Jones l

'NRC T Local.PDRs EButcher PDIII-3 r/f 1 ACRS(10)

'GHolahan . GPA/PA Mr. Alvin Kaplin, Vice President PKreutzer ARM /LFMB Nuclear Group

. TColburn Gray Files '

The Cleveland Electric illuminating .0GC-WF1 CMcCraken Company DHagan 10 Center Road EJordan -l Perry, Ohio 44081 JPartlow TBarnhart(4)

SUBJECT:

TECHNICAL SPECIFICATION CHANGE REQUEST CONCERNING PERRY NUCLEAR POWER PLANT UNIT 1 MAIN STEAM ISOLATION VALVE LEAKAGE CONTROL SYSTEM (MSIVLCS)(TACNOS.66080and67085) .

On September 18, 1987, you submitted the subject request for license amendment for the Perry Nuclear Power Plant Unit No.1. The proposed amenoment sought to eliminate the Perry Unit 1 MSIV LCS from Technical Specification requirements for surveillance and operability of the system while maintaining the system and perfonning periodic testing on the same t frequency as stated in the Technical Specifications. The proposed amend- ,

ment would also modify the MSIV leakage criteria. Additionally, you '

indicated your intention to submit a future license amendment request to i eliminate the MSIV LCS upon completion of the staff's resolution of Generic i Issue C-8, "MSIV Leakage and LCS Failure."  ;

Your basis for requesting the proposed amendment is stated to be as allowed  !

in Regulatory Guide 1.96 Section D; that is, where the applicant proposes i an acceptable alternative method for complying with specified portions of I the Comission's regulations. Specifically, the "isolated condenser" i method of operation as described in NUREG-1169 is referenced as the proposed  ;

alternative for Perry Unit 1. You indicate that a cosiparison of plant design parameters and control room and offsite dose results was conducted ,

between the. Perry Nuclear Power Plant and the reference plant in NUREG-1169.

You also compare dose contributions to the design-basis accident (DBA) from l the MSIV leakage pathway, using both the LCS and the isolated condenser mode as described in NUREG-1169. You have stated that calculation assump-tions are the same for the two methods except for treatment of the MSIV '

leakage. You then reference various modeling calculations conducted to arrive at Perry-specific values.

Y 8803150313 880311 PDR ADOCK 05000440 PDR 0

Mr. Alvin Kaplin March 11, 1988 NUREG-1169 was transmitted to all applicants and licensees of boiling water reactors (BWR's) by Generic Letter 86-17 (G.L. 86-17) dated October 17, 1986.

As stated in G.L. 86-17, "... this letter is provioed for information only.

It does not contain any new requirements or guidance for licensees of boiling water reactors..." NUREG-1169 was not Intended to be a stand-alone document describing a method for resolution of Generic Issue C-8. Rather, it was intended to provide infonc,ation in anticipation of future regulatory initi-dtives, including changes to existing regulatory guides, standard review plan sections arf if necessary the Conunission's regulations. At this stage, proposals to em; 1 / alternatives discussed in NUREG-1169 need to ossure that when applied to , articular plants, the resulting systems satisfy the require-ments of the Commission's regulations or to identify and properly support any requested exemptions.

Further, your submittal states that calculation assumptions for DBA offsite dose contributions from MSIV leakage using the LCS and using the "isolated condenser" method are the same. NUREG-1169 studies were conducted in parallel with ongoing staff initiatives in other areas including review of the existing source terms used in accident modeling. However, those initi-atives are not yet complete and do not yet form a basis for modification of licensing assumptions in this area. NUREG-1169 assumes a different source term than that used in the licensing basis for the Perry Nuclear Power Plant; e.g. all released radionuclides other than noble gases are in particulate form. This assumption is different from the licensing basis used for Perry and those in Regulatory Guide 1.3. Your application dces not provide technical justification for use of this different source term.

Lastly, your submittal p ovides conclusory findings of detailed analyses and/or tredeling studies you indicate have been conducted to support the requested amendment, However, your submittal is absent these detailed analyses and modeling studies. Thus, while you indicated that you have followed similar methodology as described in NUREG-1169 for evaluating the expected offsite doses utilizing the "isolated condenser" method for containing MSIV leakage at the Perry Nuclear Power Plant, Unit 1, the staff has no basis for confinning that such analyses and modeling were correctly completed. Thus, without such analyses and modeling studies, the staff finds your submittal to be incomplete.

Therefore, based on the above, your September 18, 1987 request for a license amendment is not acceptable to the staff.

Should you wish to resubmit this or other license amendment applications in the future, you are remindeo that the package, to be considered complete, should contain all supporting analyses and studies unless already submitted on your docket or confirmed in an identified topical report rather than merely summarizing their results. With respect to the amendment request described above, you may wish to wait until the staff has completed its

Mr. Alvin Kaplin -3 March 11, 1988 resolution of Generic Issue C-8 prior to resubmitting any similar amendment requests in order to obtain the appropriate formal regulatory guidance to assist you with your submittal.

Sincerely Q e 0. _

Kenneth E. Perkins, Director Project Directorate III-3 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation cc: See next page

• See previous concurrence ,

OFFICE: PDIII-3 PDIII-3 ECEB PDIII-3 SURNAME: PKretuzer* TColburn/rl* CMcCraken* MEPerkins*

DATE: 03/08/88 03/08/88 03/09/88 03/09/88 0FFICE: OGC-WF SURNAME:

DATE: 0,3 i

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Mr. Alvin Kaplin -

A notice of denial and opportunity for hearing, which will be forwarded to the Office of the Federal Register for publication, is enclosed.

Sincerely Kenneth E. Perkins, Director Project Directorate III-3 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation

Enclosure:

Notice of Denial ec: See next page w

0FFICE: PDJ LIO PDIII-3 RIe

• ECEB O -- PDIII-3 SURNAME: Pf&ttfzer TColburn/rl KEPerkins DATE: 03/t/88 03/$/88 CMcChaken [ 03/o9/88 03/f/88 0FFICE: OGC-WF1 SURNAME:

DATE: 03/ /88

Mr. Alvin Kaplan Perry Nuclear Power Plant The Cleveland Electric Unit 1 Illuminating Company cc:

Shaw, Pittman, Potts & Trowbridge Mr. James W. Harris, Director 2300 N Street, N.W. Division of Power Generation Washington, D.C. 20037 Ohio Department of Industrial Relations David E. Burke P.O. Box 825 The Cleveland Electric Columbus, Ohio 43216 Illuminating Company P.O. Box 5000 The Honorable Lawrence Logan Cleveland, Ohio 44101 Mayor, Village of Perry 4203 Harper Street Resident Inspector's Office Perry, Ohio 44081 U.S. Nuclear Regulatory Commission Parmly at Center Road The Honorable Robert V. Orosz Perry, Ohio 44081 Mayor, Village of North Perry North Perry Village Hall Regional Administrator, Region III 4778 Lockwood Road U.S. Nuclear Regulatory Commission North Perry Village, Ohio 44081 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attorney General Department of Attorney General Frank P. Weiss, Esq. 30 East Broad Street Assistant Prosecuting Attorney Columbus, Ohio 43216 105 Main Street Lake County Administration Center Radiological Health Program Painesville, Ohio 44077 Ohio Department of Health 1224 Kinnear Road Ms. Sue Hiatt Columbus, Ohio 43212 OCRE Interim Representative 8275 Munson Ohio Environmental Protection Mentor, Ohio 44060 Agency 361 East Broad Street Terry J. Lodge, Esq. Columbus, Ohio 43266-0558 618 N. Michigan Street Suite 105 Mr. James R. Secor, Chairman Toledo, Ohio 43624 Perry Township Board of Trustees Box 65 ,

John G. Cardinal, Esq. 4171 Main Street Prosecuting Attorney Perry, Ohio 44081  !

Ashtabula County Courthouse Jefferson, Ohio 44047 State of Ohio -

Public Utilities Commission Eileen M. Buzzelli 180 Fast Broad Street The Cleveland Electric Columbus, Ohio 43266-0573 Illuminating Company P. O. Box 97 E-210 Mr. Murray R. Edelman Perry, Ohio 44081 Centerior Energy '

6200 Oaktree Blvd.

Independence, Ohio 44131 ,

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Atomic Safety and Licensing Board Panel U.S. Nuclect Regulatory Commission Washington, D.C; 20555 Atomic Safeti ..d Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washingtun, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Donald T. Ezzone, Esq.

Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 Janine Migden, Esq.

Ohio Office of Consumers Counsel 137 E. State Street Columbus, OH 43215

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