ML20198H555

Safety Evaluation Supporting Amend 86 to License NPF-58

ML20198H555
Person / Time
Site:	Perry
Issue date:	09/09/1997
From:	NRC (Affiliation Not Assigned)
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ML20198H553	List: ML20198H547 ML20198H555
References
NUDOCS 9709190078
Download: ML20198H555 (4)

Text

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NUCLEAR F1EGULATORY COMMISSION WASHINGTON, D.C. 30MH001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 86 TO FACILITY OPERATING LICENSE NO. NPF 58 THE CLEVELAND ELECTRIC lllUMINATING COMPANY. ET AL.

PERRY NUCLEAR POWER PLANT. UNIT NO. 1 DOCKET NO. 50 440

1.0 INTRODUCTION

On September 12, 1995, the U.S. Nuclear Re ulatory Comission (NRC) approved issuance of a revision to 10 CFR Part 50, pendix J. "Primar Containment Leakage Testing for Water-Coole Power Reactors,"y Reactor which was subsequently published in {he Federal Reaister on September 26, 1995, and became effective on October 26. 1995, lhe NRC added Option B " Performance-Based Requirements." to allow licensees to voluntarily replace the prescriptive testing requirements of 10 CFR Part 50, Appendix J, with testing recuirements based on both overall performance and the performance of incividual components.

By letters dated January 31 and August 6,1997, The Cleveland Electric Illuminating Company (the licensee) requested changes to the Technical Speci fication: (TS) for the Perry Nuclear Power Plant.

The proposed changes would permit implementation of 10 CFR Part 50. A)pendix J. Option B.

The licensee has established a " Primary Containment eak @ Rate Testing Program" and proposed adding this program to the TS.

The program references Regulato*,y Guide 1,163. " Performance-Based Containment Leak-Test Program." dated September 1995, which specifies a method acceptable to the NRC for complying with Option B.

The supplemental letter made two minor changes to the proposed TS by adding the approval date of Regulatory Guide 1.163, and by adding the numerical value of the peak calculated containment pressure.

These minor additions did not substantially change the application or affect the proposed no significant hazards determination.

2.0 BACKGROUND

_ Compliance with 10 CFR Part 50. Appendix J. provides assurance that the primary containment including those systems and components which penetrate the primary containment, do not exceed the allowable leakage rate specified in the TS and Bases. The allowable leakage rate is determined so that the leakage rate assumed in the safety analyses is not exceeded.

OnFebruary4.1992,theNRCpublishedanoticeintheEgderalReaister (57 FR 4166) discussing a planned initiative to begin eliminating requirements marginal to safety that impose a significant regulatory burden. Appendix J to l

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2-10 CFR Part 50. " Primary Containment Leakage Testing for Water Cooled Power Reactors." was considered for this initiative and the staff undertook a study of possible ch3nges to this regulation. The study examined the previous performance N story of domestic containments and examined the effect on risk of a revision to the recluirements of Appendix J.

The results of this study are reported in NUREG 1493. " Performance Based Leak-Test Program."

Based on the results of this study, the staff developed a performance based approach to containment leakage rate testing. On September 12, 1995, the NRC ap> roved issuance of this revision.to 10 CFR Part 50. Ap)endix J which was su)sequently published in the Federal Reaister on Septemaer 26. 1995, and became effective on October 26, 1995.

The revision added Option B.

" Performance Based Requirements." to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements based on both overall and individual component leakage rate performance.

Regulatory Guide 1.163. " Performance Based Containment Leak Test Program."

dated Septemb.- 1995, was developed as a method acceptable to the NRC staff for implementing 0) tion B.

This regulatory guide states that the Nuclear Energy Institute (1EI) guidance document NEl 94 01. Rev. O. " Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50.

Appendix J." provides methods acce) table to the NRC staff for complying with Option B with four exceptions whic1 are described therein.

Option B requires that Regulatory Guide 1.163 or another implementation document used by a licensee to develop a performance-based leakage testing 3rogram must be included by general reference, in the plant TS. The licensee las referenced Regulatory Guide 1.163 in the proposed Perry TS.

Regulatory Guide 1.163 specifies an extension in Type A test frequency to at least one test in 10 years based upon two consecutive successful tests.

Type B tests may be extended up to a maximum interval of 10 years based upon completion of two consecutive-successful tests and Type C tests may be extended up to 5 years based on two consecutive successful tests.

By letter dated October 20. 1995, NEl proposed TS to implement 0) tion B.

After some discussion, the staff and NEI agreed on final TS whic1 were transmitted to NEl in a letter dated November 2.1995. These TS are to serve as a model for licensees.to develop plant specific TS in preparing amendment requests to implement Option B.

In order for a licensee to determine the performance of each component, factors that are indicative of or affect performance, such as an administrative leakage limit, must be established. The administrative limit is selected to be indicative of the potential onset of component degradation.

Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements.

Failure to meet an administrative limit requires the licensee to return to the minimum value-of the test interval.

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4 3-Option B requires that the licensee maintain records to show that the criteria for Type A, B, and C tests have been met.

In addition, the licensee must maintain comparisons of the performance of the overall containment system and the individual components to show that the test intervals are adequate. These records are subject to NRC inspection.

3.0 EVALUATION The licensee's January 31 and August 6, 1997, letters to the NRC propose to establish a " Primary Containment Leakage Rate Testing Program" and propose to add this program to the TS. The program references Regulatory Guide 1.163,

" Performance Based Containment Leak Test Program," dated September 1995, which specifies methods acceptable to the NRC for complying with Option B.

This requires changes to existing TS 1.1, 3.6.1.1.1, 3.6.1.2.1, 3.6.1.3, and 3.6.5.1, and the addition of the " Primary Containment Leakage Rate Testing Program" as TS 5.5.12.

Corresponding Bases will also be modified.

Option B permits a licensee to choose Type A: Ty>e B and C: or Type A, B, and C: testing to be done on a performance basis.

T1e 1 M nsee has elected to perform Type A, B, and C testing on a performance oasis l The TS changes proposed by the licensee are in compliance with the requirements of Option B and consistent with the guidance of Regulatory Guide 1.163, with two exceptions noted by the licensee: these are discussed in Sections 3.1 and 3.2, below.

Further, the proposed TS changes conform to the model TS guidance provided in the NRC letter to NEl dated November 2.-1995, and are, therefore, acceptable to the staff.

3.1 Use of Bechtel Tooical Reoort BN-TOP-1 NEl 94-01, Section 8.0, " Testing Methodologies for Type A, B, and C Tests,"

states that these tests should be perfe'ined using the technical methods and techniques specified in ANSI /ANS 56.8-1994, "or other alternative testing methods that have been approved by the NRC." Some licensees wish to use the alternative testing methodology contained in Bechtel Topical Report BN-TOP 1,

-Revision 1. " Testing Criteria For Integrated Leakage Rate Testing of Primary Containment Structures For Nuclear Power Plants " dated November 1, 1972. The staff approved use of BN TOP-1 in 1972 and it has been used ever since, primarily-because it allows Type A tests to be completed in as little as

-6 hours instead of the typical 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Although Option B and ANSI /ANS

-56.8-1994 allow tests as short as 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and may be preferable to the dated methodology of BN TOP-1, the licensee proposes to retain BN-TOP-1 as an option for performing Type A tests.

BN TOP-1 still provides acce) table results and, therefore, continues to be acceptable for plants under eitler Option A or Option B of Appendix J.

The proposed TS describe the use of BN-TOP-1 as an exception to Regulatory Guide 1.163.

Strictly speaking, the use of BN-TOP-1 does not constitute an exception to Regulatory Guide 1.163: it conforms to the provision, quoted above, that allows other alternative testing methods that have been approved p

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. by the NRC. Nevertheless, the staff has no objection to specifically citing CN TOP-1 in the TS so as to avoid any confusion as to its acceptability.

Therefore the staff finds the proposed TS concerning BN TOP-1 to be acceptable.

3.2 Errata to NEl 94 01 The licensee's second proposed exception to Regulatory Guide 1.163 is stated as follows:

The corrections to NE! 94 01. which are identified on the Errata Sheet attached to the NEl letter. " Appendix J Workshop Questions and Answers."

dated March 19, 1996, are considered to be an integral part of NEl 94-01.

The cited Errata Sheet is identical to the one issued by the staff on March 6, 1996, to the regulatory guide distribution list: the letter was entitled.

" Changes to NEl 94 01. Revision 0."

The letter stated that the Errata Sheet was acceptable to the staff.

The proposed TS describe the use of the Errata Sheet as an exception to Regulatory Guide 1.163. The staff does not consider the use of the Errata Sheet to be an exception to Regulatory Guide 1.163: the staff considers the corrections contained in the Errata Sheet to be an integral part of NEl 94 01.

Rev. 0, and nearly all other licensees that have adopted Option B do not mention the Errata Sheet in their staff-a> proved TS.

Nevertheless, the staff has no objection to specifically citing tie Errata Sheet in the TS so as to avoid any confusion as to its acceptability. Therefore, the staff finds the proposed TS concerning the Errata Sheet to be acceptable.

3.3 Summary In summary, the staff has reviewed the changes to the TS and associated Bases proposed by the licensee and finds that they are in compliance with the requirements of Appendix J. Option B and are consistent with the guidance of Regulatory Guide 1.163, with the two exce)tions reviewed above, and conform to the model TS, and are. therefore, accepta)le.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment.

The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment involves changes to surveillance requirements.

The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that pay be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a

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l proposed finding that this amendment involves no signifit;nt hazards consideration and there has been no public comment on such finding (62 FR 11492). Accordingly, this amendment meets _the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental im)act statement or environmental assessment need be prepared in connection wit 1 the issuance of this amendment.

6,0 CONCLUSION The staff has concluded, based on the considerations discussed abos?. that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the pro)osed manner: (2) such activities will be conducted in compliance witl the Commission's regulations:

and (3) the issuance of this anendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

J. Pulsipher Date:

September 9, 1997 i

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