PY-CEI-NRR-2370, Provides Addl Info Re FW Penetration Improvement Lar,Dtd 990106.Licensee Has Determined That Exemption to 10CFR50,App J Is Not Necessary,As Requested in Subject Ltr.Revised TS, Bases & USAR Pages,Encl
| ML20207K094 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/04/1999 |
| From: | Myers L CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20207K097 | List: |
| References | |
| PY-CEI-NRR-2370, TAC-MA3487, NUDOCS 9903170049 | |
| Download: ML20207K094 (2) | |
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o4 08 Lew W Myers 440-280-591S Vice President Fax:440-280-8029 March 4,1999 PY-CEl/NRR-2370L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 Second Supplement to a License Amendment Request: Improved Licensing and Design Basis For Isolation of the Feedwater Penetrations (TAC No. MA3487)
I Ladies and Gentlemen:
This leter provides additional information on the Feedwater Penetration Improvement license amendment request dated January 6,1999 (PY-CEl/NRR-2352L). The January 6 letter i
superceded (in its entirety) a letter submitted on September 9,1998 (PY-CEl/NRR-2322L).
Based on discussions with the Nuclear Regulatory Commission (NRC) staff, it has been determined that an Exemption to 10 CFR 50 Appendix J, as requested in the letter dated January 6,1999, is not necessary. In addition, it has been determined that one commitment from that letter will be revised. The revised commitment includes a provision that the test performed on the Feedwater System containment isolation check valves to satisfy the Inservice l
Testing Program requirements will include a water leak rate test. The attachments to this letter provide the necessary changes as a result of the discussions with the NRC staff. provides the update to the commitment. Attachment 2 contains revised Technical Specification and Bases pages (the Bases pages are for information only, since the Bases are revised by site procedures). Attachment 3 provides revised USAR pages. The pages in Attachments 2 and 3 include only the pages that were revised since the letter dated January 6,1999. The other Technical Specification, Bases, and USAR pages that were included with the letter dated January 6,1999, are unchanged and remain valid.
Although the Significant Hazards Consideration in the letter dated January 6,1999 did not mention this additional commitment to perform a hydrostatic test, the Significant Hazards Consideration was reviewed and was determined to remain valid.
If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager - Regulatory Affairs, at (440) 280-5606.
Very truly yours,
' 4cJ N & 40 l
3 GOO Attachments cc: NRC Project Manager d
O NRC Resident inspector NRC Region til' State of Ohio 9903170049 990304
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PDR ADOCK 05000440:
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Attchment 1 l
PY-CEl/NRit-2370L l
Pgge 1 cf 1 Revis' d Commitment on Testina of the Feedwater Containment isolation Check Valves e
l In a letter dated January 6,1909 (PY-CEl/NRR-2352L), the following commitment was included:
Previous Commitment " Generic Letter (GL) 89-04 Position 3 "Back Flow Testing of Check Valves" noted that tests on check valves that perform a safety function in the closed position to prevent reversed flow should be performed. " Category C" tests on such " safety function check valves" were described as needing to prove that the disc closes on its seat. An example method 1
discussed in GL 89-04 for such safety function Category C tests is a visual observation. It is
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proposed that the Feedwater Check Valves be Category C tested for ineir safety function by performance of a visualinspection of the valve intemals at an appropriste frequency as determined by the Inservice Testing Program (ISTP). A tap will be added adjacent to each check valve to permit vist,al inspections under the seat of the valves to verify proper closure. This inspection would constitute the " exercise closed (EC)" test in the ISTP. The " exercise open (EO)" testing would remain the same, i.e., the valves pass proper flow during plant operation."
It is proposed that the above commitment be revised to read as follows:
1 Revised Commitment " Generic Letter (GL) 89-04 Position 3 "Back Flow Testing of Check Valves" notes that tests on check valves that perform a safety function in the closed position to prevent reversed flow should be performed. " Category C" tects on such " safety function check valves" were described as needing to prove that the disc closes on its seat. Two example methods discussed in GL 89-04 for such safety function Category C tests are visual observations or leak rate testing. It is proposed that the Feedwater containment isolation check valves be Category C tested for their safety function at an appropriate frequency as determined by the Inservice Testing Program (ISTP). Leak rate testing will satisfy the " exercise closed (EC)" test requirements of the ISTP. The EC testing will include a water leak rate test, with an acceptance criteria of s 200 gallons per minute per Feedwater penetration, when tected at 21.1 P.."
The other commitments listed in the January 6,1999 letter remain valid.
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