ML20198S306

Summary of 981204 Meeting with Util in Rockville,Md to Discuss Proposed Changes to Design & Licensing Basis of Containment Isolation Provisions for Feedwater Sys

ML20198S306
Person / Time
Site:	Perry
Issue date:	01/05/1999
From:	Pickett D NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9901110258
Download: ML20198S306 (15)

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UNITED STATE 8 j

NUCLEAR RESULATORY COMMISSION WASHINGTON, D.C. 20066 4001 January 5, 199 LICENSEE: Cleveland Electric illuminating Company FACILITY:

Perry Nuclear Power Plant, Unit No.1

SUMMARY

OF DECEMBER 4,1998 MEETING ON FEEDWATER ISOLATION PROVISIONS

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On December 4,1998, NRC staff met with representatives of The Cleveland Electric illuminating Company (CEI) in Rockville, Maryland. The purpose of the meeting was to discuss proposed 1

changes to the design and licensing basis of the containment isolation provisions for the feedwater system. A list of the meeting participants is included as Enclosure 1. The meeting handouts are included in Enclosure 2.

The meeting, which was a followup to the meeting held on November 19,1998, between the i

staff and the licensee on the same subject, received increased management attention. The licensee described the feedwater check valve history and their intentions to resolve this problem i

in advance of the seventh refueling outage. The feedwater check valves are 20-inch valves which are not designed to be leak tight in the 8 psi post-LOCA containment environment. The licensee stated that for all accidents etw than a feedwater line break, feedwater flow will be maintained to the reactor vessel and the check valves will not be required to close. While describing their efforts to meintain the check valves leak tight, the licensee noted the associated high costs and man-rem exposures. In particular, potentially hazardous situations are involved when personnel are required to hang upside down in order to polish valve seats.

The staff reiterated several of their positions that were made during the meeting of i

November 19,1998. Specifically, Supplement 7 to the original Safety Evaluation Report does not preclude the single active failure of the outside gate valve to closs; dual isolation barriers would be needed to satisfy General Design Criterion 56 for the feedwater penetration; an exemption to Appendix J of 10 CFR 50 would be needed if the feedwater isolation valves would not be leak rate tested; and the staff still considered injection of the feedwater leakage control system between the three isolation valves of the feedwater system to be desirable in order to maintain a water seal thus precluding air leakage.

Discussions focused on a permanent fix as opposed to a one-time scheduler exemption from the local leak rate testing requirements of Appendix J that was recommended by the staff during the meeting of November 19,1998. Any such action would be precedent setting and would receive close review by the staff. While the staff and licensee did not reach a final resolution, any submittal would need to includa e xemptions from the appropriate regulations, most, if not all of the modifications proposed by the Mensee in the original submittal (e.g., dual power supplies j

to the outside gate valves, and reroutir,g of the feedwater leakage control system to the stem of l

the outside gate valves), and a risk-informed discussion justifying the proposed actions. The I

risk-informed discussion would need to address the probability and consequences of the outside gate valve failing to close.

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I 2-i Following the meeting, the licensee informed the staff of their intent to prepare a new submittal that would supercede their previous proposal. The licensee expected to make this submittal at approximately the end of the month.

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Douglas V. Pickett, Senior Project Manager Project Directorate lll-2 Division of Reac'or Projects ill/IV Office of Nuclear Reactor Regulation Docket No. 50-440 L

Enclosures:

List of Meeting Participants Meeting Handouts cc w/encis: See next page i

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. January 5, 1998 Following the meeting, the licensee informed the staff of their intent to prepare a new submittal that would supercede their previous proposal. The licensee expected to make this submittal at approximately the end of the month.

Original signed by:

Douglas V. Pickett, Senior Project Manager Project Directorate Ill-2 Division of Reactor Projects Ill/lV Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosures:

List of Meeting Participante Meeting Handouts cc w/encis: See next page DISTRIBUTION:

Hard Coov w/encls E-mail w/EncI 1 Docket File SCollins (SJC1)

JKudrick EAdensam PD lil-2 Reading RZimmerman EThrom PUBLIC THiltz CBerlinger GGrant, Rill BBoger -

GHolahan Hard Coov w/Enct 1 OGC ACRS DOC'UMENT NAME: ' G:\\ PERRY \\MTG12 04. SUM Ta receive a copy of this document, indicate in the box:

"C" = Copy without enclosures "E" = Copy with enclostpies "N" = No copy OFFICE PM:PQII,Ig2 C.

LA:PDIII-2 6 D:PDIII-2 C

BC:S9$0/]f NAME DPicfett' EBarnhill 9/r" SRichards 6@

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DATE 12/21/98 12/d@/98-

%4 /9ff 99 52/6(/99 12/ /98 0FFICIAL RECORD COPY

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3,7 January 5, 1998 l.

L Following the meeting, the licensee informed the staff of their intent to prepare a new submittal l __

that would supercede their previous p:oposal. The licensee expected to make this submittai at l

approximately the end of the month.

Original signed by:

Douglas V. Pickett, Senior Project Manager Project Directorate ill-2

' Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation

. Docket No. 50-440 g

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Enclosures:

List of Meeting Participants Meet;ng Handouts cc w/encis: See next page DISTRIBUTION-Hard Coov w/encls E-mail w/ Encl 1 Docket File SCollins (SJC1)

JKudrick EAdensam PD 111-2 Reading RZimmerman EThrom i

PUBLIC THiltz CBerlinger GGrant, Rlll BBoger GHolahan Hard Copy.gEnci 1 OGC ACRS DOC'UMENT NAME: G:\\ PERRY \\MTG12 04. SUM

- To receive a copy of this document, Indicate in the boa: "C" = Copy without enciosures *E = Copy with enclostges *N* = No copy 0FFICE PM:PDII,lo2 E

LA:PDIII-2 6 D:PDIII-2 L

BC:SydB[/f L

NAME DPi fett' EBarnhill@/r*

SRich3rds 6 @

CBerEn'deV DATE-12/2't/98 12////98

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OFFICIAL RECORD COPY i

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C:ntIrior S2rvice Comp;ny Ptrry Nucinr Pow 2r Pitnt, Units 1 and 2

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. Mary E. O'Reilly James R. William; i

FiratEnergy - A290 Chief of Staff l

10 Center Road Ohio Emergency Management Agency Perry, OH 44081 2855 West Dublin Granville Road l

Columbus, OH 43235-2206 Resident inspector's Office L

U.S. Nuclear Regulatory Commission Donna Owens, Director P.O. Box 331' Ohio Department of Commerce Perry, OH 44081-0331 Division of Industrial Compliance Bureau of Operations & Maintenance Regional Administrator, Region 111 6606 Tussing Road j

U.S. Nuclear Regulatory Commission P.O. Box 4009 801 Warrenville Road Reynoldsburg, OH 43068-9009 Lisle, IL 60532-4531 Mayor, Village of North Perry l

Sue Hiatt -

North Perry Village Hall l

OCRE Interim Representative 4778 Lockwood Road 8275 Munson North Perry Village, OH 44081 l

Mentor, OH 44060 Radiological Health Program Henry L. Hegrat Ohio Department of Health l

Regulatory Affairs Manager P.O. Box 118 l

Cleveland Electric illuminating Co.

Columbus, OH 43266-0118 Perry Nucl ear Power Plant l

P.O. Box 97, A210 Ohio Environmental Protection l

Perry, OH 44081 Agency DERR-Compliance Unit i

Lew W. Myers ATTN: Mr. Zack A. Clayton l

Vice President Nuclear, Perry P.O. Box 1049 l

Centerior Service Company Columbus, OH 43266-0149 l

P.O. Box 97, A200 l

Perry, OH 44081 Chairman Perry Township Board of Trustees i

Mayor, Village of Perry 3750 Center Road, Boy 65 P.O. Box 100 Perry, OH 44081 Perry, OH 44081-0100 L

State of Ohio l

FirstEnergy Corporation Public Utilities Commission Michael Beiting East Broad Street Associate General Counsel Columbus, OH 43266-0573 76 5. Main Akron, OH.44308 William R. Kanda, Jr., Plant Manager Cleveland Electri.- Illuminating Co.

l' Perry Nuclear Power Plant P.O. Box 97, SB306 Perry, OH 44081 i

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MEETING ATTENDEES NRC AND CLEVELAND ELECTRIC ILLUMINATING COMPANY FEEDWATER ISOLATION PROVISIONS DECEMBER 4,1998 CLEVELAND ELECTRIC ILLUMINATING CO.

Lew Myers

. Howard Bergendahl Bradley S. Ferrell Henry Hegrat -

Thomas Shega NBC Roy Zimmerman Bruce Boger Scott Newberry Carl Berlinger Ed Throm Adel El-Bassioni Nick Saltos Stuart Richards Doug Pickett l

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e Feedwater Penetration Improvement Goal: Reach a mutual understanding of the l

Feedwater penetration improvement issue Summary of current licensing basis

>> Review of options that were considered l

>> Review of the present proposal n Review of NRC discussions at the mid-November meeting Project Goal: to improve the overall performance of the Feedwater Penetrations Reduce actual dose to plant workers Improve protection of the public n Provide a risk-informed level of protection to achieve the above goals Page 2

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Feedwater Penetration Improvement

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'l Present Licensing Basis:

l Check Valves primarily for FW break outside containment i

Other event is LOCA. For dos'e calculations, we depend on mitigation by closure of the gate valves (licensing post-LOCA dose cales only consider the gate valve leakage, not t

the checks)

Gate valve seats have been very leak tight - no rework Check valve leakage criteria of < 1 gpm is required to meet the current FWLCS design function of filling the pipe within one hour, not for dose cale reasons Workers were exposed to > 5 rem to work on the check valve seats in RFO6; plus dose from testing Page 3

a Feedwater Penetration Improvement

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l Ontions considered

>> Add Soft-seats to the Check Valves, and maintain the j

current licensing basis (CLB) i Various design changes to seat Check Valves more tightly at low dP's, or install a different kind of check valve, and maintain CLB

>> Maintain current FWLCS injection point, and increase allowable Check Valve leakage l

>> Provide alternate power supply to existing gate valves, & relocate FWLCS to gate valve bonnet

>> Design & install a new " sister" gate valve in each line i

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Feedwater Penetration Improvement Benefits of new design u

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>> Improves the probability of the Feedwater lines getting ll a water seal within the currently licensed period of time after a LOCA due to relocated FWLCS

>> Improves the probability of closure of the currently j

licensed high integrity gate valves, after a LOCA/ LOOP /Div.1 failure, due to new provisions for l

an alternate power supply Reduces the dose received by workers who have been j

performing maintenance and testing of the checks Proposal continues to provide protection for a postulated Feedwater Line Break Outside Containment Page5 u

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Feedwater Penetration Improvement

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Difficulties with other options i

>> Soft seated check valves j

>> Various design changes to seat existing check valves more tightly, or to' replace with a different j

style check valve

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Maintain current FWLCS injection point, and i

i increase allowable check valve leakage l

Design & install a new safety-related, Class 2

" sister" gate valve in each line (See next page for l

more details on the difficulties with this concept) j i

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9 Feedwater Penetration Improvement

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Difficulties with other options (continued)

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n Design & install a new safety-related, Class 2 " sister" gate valve in l

each line l!

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penetration as compared to the proposed change (proposed change will

- Would provide very little benefit to the post-LOCA reliability of the provide an alternate power supply to the existing gate valves, and give the operators more time to start FWLCS).

Frequency of Core Damage from all internal initiating events is 1.4E-5 per year (Baseline CDF)

Frequency of Core Damage from LOCA is SE-8.

Frequency of Core Damage from LOOP is 5.7E-6.

Probability of failure to establish a water seal within one hour of Core Damage Accident is:

Offsite Power Available With LOOP Current Design

• 0.27 0.28 P oposed Design 0.042 0.069 Two MOV Design 0.036 0.048

• for the " Current Design" numbers, it was conservatively assumed that a water seal between the check valves, with the gate valve open, is a " success" Page 7

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Feedwater Penetration Improvement j

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Difficulties with other options (continued) i

>> Design & install a new safety-related, Class 2 i

" sister" gate valve in each line (continued)

- Would not factor in to the analysis of the Feedwater line break outside containment.

- No room for a new valve in the current Class 2 piping i

boundary. Areajust outside of Class 2 is very tight.

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- Would require relocation of the Feedwater venturies, huge pipe restraints, substantial amount of welding.

- Would be a high dose job, and extremely expensive.

- The cost-benefit ratio does notjustify this change.

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Feedwater Penetration Improvement

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i Conclusions i

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>> The proposed design change willimprove the l

reliability of the Feedwater le.akage control system.

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>> The additional reliability benefit of the "two MOV alternative" is negligible when considered in the context of the frequency of a core damage event, which must first occur before there is any need to isolate the Feedwater penetration.

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