ML20245K395

Forwards Request for Addl Info on Amend to License NPF-58 Re Changing Primary Containment Leakage Rate Limit.Addl Info Must Be Provided within 45 Days of Receipt of Ltr

ML20245K395
Person / Time
Site:	Perry
Issue date:	08/10/1989
From:	Colburn T Office of Nuclear Reactor Regulation
To:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
References
TAC-72640, NUDOCS 8908180439
Download: ML20245K395 (5)

Text

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August 10, 1989 Docket No. 50-440 Distribution 4

. ; Docket File 3 TColburn Mr. Alvin Kaplan, Vice President NRC & Local PDRs OGC Nuclear Group PDIII-3 r/f EJorden The Cleveland Electric Illuminating MVirgilio BGrimes Company JHannon ACRS(10) 10 Center Road PKreutzer PDIII-3 Gray Perry, Ohio 44081

SUBJECT:

MAIN STEAM ISOLATION VALVE (MSIV) LEAKAGE LIMITS T.S.

CHANGE REQUEST, REQUEST FOR ADDITIONAL INFORMATION (TACNO.72640J By letter dated September 18, 1987 as supplemented April 8, 1988, you requested a license amendment for the Perry Nuclear Power Plant, Unit No. I which, in i part,proposedamodificatior,ofTechnicalSpecification(TS)3.6.1.2.c. The j proposed amendment would change the primary containment leakage rate limit from less than or equal to 25 SCFH (standard cubic feet per hour) for any one main steam line through the isolation valves when tested at P , 11.31 psig, to less than or equal to 100 SCFH for all (four) main steam line$.

By [[letter::PY-CEI-NRR-0982, Provides Addl Info & Commitment Re Request to Revise Tech Spec 3.6.1.2.c Concerning Main Steam Line (MSL) Leakage Limits.Util Will Keep Current Limit Below 200 Scfh for All MSLs & Commits to Administrative Limit on Individual MSLs|letter dated March 6,1989]] you provided supplementary information related to your request. We have reviewed your [[letter::PY-CEI-NRR-0982, Provides Addl Info & Commitment Re Request to Revise Tech Spec 3.6.1.2.c Concerning Main Steam Line (MSL) Leakage Limits.Util Will Keep Current Limit Below 200 Scfh for All MSLs & Commits to Administrative Limit on Individual MSLs|March 6,1989 letter]] and request clarification of certain statements made in that letter plus additional

! information, both of which are identified in the enclosure to this letter. We request th9t you respond with the additional information and clarification within 45 days of receipt of this letter.

This request for information affects fewer than 10 respondents. Therefore, OMB clearance is not required under Pub. L.96-511.

Sincerely,

/s/

l Timothy G. Colburn, Senior Project Manager Project Directorate III-3 Division of Reactor Projects - III, l IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information Of0I cc w/ enclosure: I See next page

• SEE PREVIOUS CONCURRENCE Office: *LA/PDIII-3 *PM/PDIII-3 *ECEB B PD/PDLII-3 Surname: PKreutzer TColburn/mr CMcCracken Cunn n ham annon Date: 7/12/89 7/13/89 7/20/89 g/g89 /g/89 8908180439 ADOCK890810 05000440; DR

Docket No. 50*440 Distribution Docket File TColburn Mr. Alvin Kaplan, Vice President NRC & Local PDRs OGC Nuclear Group PDIII-3 r/f EJordan The Cleveland Electric Illuminating MVirgilio BGrimes Company JHannon ACRS(10) 10 Center Road PKreutzer PDIII-3 Gray Perry, Ohio 44081

SUBJECT:

MAIN STEAM ISOLATION VALVE (MSIV) LEAKAGE LIMITS T.S.

CHANGE REQUEST REQUEST FOR ADDITIONAL INFORMATION (TACNO.72640 By letter dated September 18, 1987 as supplemented April 8,1988, you requested a license amendment for the Perry Nuclear Power Plant, Unit No. I which, in part, propcsed a modification of Technical Specification (TS) 3.6.1.2.c. The proposed amendment would change the primary containment leakage rate limit from less than or equal to 25 SCFH (standard cubic feet per hour) for any one main stcam line through the isolation valves when tested at P ,11.31 psig, to less thanorequalto100SCFHforall(four)mainsteamlinef.

By [[letter::PY-CEI-NRR-0982, Provides Addl Info & Commitment Re Request to Revise Tech Spec 3.6.1.2.c Concerning Main Steam Line (MSL) Leakage Limits.Util Will Keep Current Limit Below 200 Scfh for All MSLs & Commits to Administrative Limit on Individual MSLs|letter dated March 6,1989]] you provided supplementary information related to your request. We have reviewed your [[letter::PY-CEI-NRR-0982, Provides Addl Info & Commitment Re Request to Revise Tech Spec 3.6.1.2.c Concerning Main Steam Line (MSL) Leakage Limits.Util Will Keep Current Limit Below 200 Scfh for All MSLs & Commits to Administrative Limit on Individual MSLs|March 6,1989 letter]] and request clarification of certain statements made in that letter plus additional information, both of which are identified in the enclosure to this letter. We request that you respond with the additional information and clarification within 45 days of receipt of this letter.

This request for information affects fewer than 10 respondents. Therefore, OMB clearance is not required under Pub. L.96-511.

Sincerely, Timothy G. Colburn, Senior Project Manager Project Directorate III-3 Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page

%s-Ofiice: LA/PDIN-3 PM/PDIII-3 ECE- .%, PRPB PD/PDIII-3 Surname: Psf'reutier TColburn/mr cmc acken Cunningham JHannon Date: 7 / g)S9 7 /d /89 f/,%/89 / /89 / /89 0f(ll%

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Mr. Alvin Kaplan Perry Nuclear Power Plant The Cleveland Electric Unit 1 '

Illuminating Company cc: Jay E. Silberg, Esq. Mr. James W. Harris, Director Shaw, Pittman, Potts & Trowbridge Division of Power Generation 1 2300 N Street, N.W. Ohio Department of Industrial l Washington, D.C. 20037 Relations )

P. O. Box 825 David E. Burke Columbus, Ohio 43216 The Cleveland Electric Illuminating Company The Honorable Lawrence Logan P.O. Box 5000 Mayor, Village of Perry Cleveland, Ohio 44101 4203 Harper Street Perry, Ohio 44081 Resident Inspector's Office U.S. Nuclear Regulatory Commission The Honorable Robert V. Orosz Parmly at Center Road Mayor, Village of North Perry Perry, Ohio 44081 North Perry Village Hall 4778 Lockwood Road Regional Administrator, Region III North Perry Village, Ohio 44081 U.S. Nuclear Regulatory Commission 799 Roosevelt Road Attorney General Glen Ellyn, Illinois 60137 Department of Attorney General 30 East Broad Street Frank P. Weiss, Esq. Columbus, Ohio 43216 i Assistant Prosecuting Attorney 105 Main Street Radiological Health Program i Lake County Administration Center Ohio Department of Health Painesville, Ohio 44077 1224 Kinnear Road Columbus, Ohio 43212 lis. Sue Hiatt OCRE Interim Representative Ohio Environmental Protection 8275 Munson Agency

• Mentor, Ohio 44060 361 East Broad Street Columbus, Ohio 43266-0558 Terry J. Lodge, Esq.

618 N. Michigan Street Mr. Phillip S. Haskell, Chairman Suite 105 Perry Township Board of Trustees Toledo, Ohio 43624 Box 65 4171 Main Street John G. Cardinal, Esq. Perry, Ohio 44081

-Prosecuting Attorney Ashtabula County Courthouse State of Ohio Jefferson, Ohio 44047 Public Utilities Commission 180 East Broad Street l 1

Robert A. Newkirk Columbus, Ohio 43266-0573  :

Cleveland Electric l Illuminating Company Michael D. Lyster Perry Nuclear Power Plant Cleveland Electric P. O. Box 97 E-210. Illuminating Company  :

Perry, Ohio 44081 Perry Nuclear Power Plant  ;

P. O. Box 97 SB306 Perry, Ohio 44081  ;

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Enclosure REQUEST FOR ADDITIONAL INFORMATION Discussion The staff's May 1982 Safety Evaluation Report (SER) calculated in Table 15.1 for the loss-of-coolant accident at Perry Unit I a total 2-hour dose at the exclusion area boundary of 6.6 rems whole body and 88 rems to the thyroid.

These are approximately 26% and 29%, respectively, of the 10 CFR 100.11 limits for determining the exclusion area boundary. As stated on page 15-8 of the SER, "An important assumption used in the staff's LOCA evaluation is that the contribution to the offsite radiological consequences from the main steamline isolation valve (MSIV) leakage control gystem was limited to that resulting

'r.im a MSIV leak rate of 25 standard f t / hour / valve. This assumption is based upon the Perry Technical Specification for MSIV leakage and presumes that the periodic testing and surveillance requirements of the Perry specifications will limit potential MSIV leakage following an accident to less than the maximum Technical Specification."

During the recent refueling outage at Perry, all four main steam lines had leak rates in excess of the Technical Specification (TS) limit of 25 standard cubic feet per hour (SCFH) per line. The leak rates ranged from 64 to 265 SCFH per line. To reduce leakage rates to less than the TS limit, it was necessary to perform maintenance on five of eight MSIV's. The exact csuse of the leakage has not yet been determined. Some of the leakage can be attributable to other valves which also form the testing boundary such as MSIV leakage control valves (three of four requiring maintenance following testing) and outbound MSIV drain valves (one of four requiring maintenance following testing). However, the contribution of these valves to the overall leakage is unknown but is presumed small due to their relative small size compared to an MSIV. In addition to the recent poor performance of the MSIV's, following the previous leak rate test, five of eight MSIV's also required maintenance. In two of the tests the leakage was too high to quantify with the installed testing rig. While leak rate testing data presented to the staff by the BWR Owners Group in July of 1987 shows a generally improving trend in leak rate testing of MSIV's on an industry-wide basis, both in total number of failures, failure percentages of those tested that failed, and maximum failure rates in SCFH, Perry's MSIV's appear to be in the lower third of industry-wide performance and do not exhibit marked improvement. Because this is a new plant, there also does not appsar to exist a significant wear factor on the valves by which major refurbishment could expect to dramatically improve future leakage performances. Given this MSIV leakage history at Perry:

1. Show that changing the leakage rate from 25 SCFH per line to 100 SCFH total will not increase the potential that total MSIV leakage will exceed 100 SCFH at any time during the operating cycle. Use both industry data and Perry valve performance data to conservatively calculate expected leak rate ranges considering previous as-left leakages and subsequent test results. Include the potential effect of raising the as-left leakage

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i in a'line to beyond 25 SCFH (current limit) in determining the total expected NSIV leakage.

2. Should the potential exist for increasing the MSIV leakage beyond that currently assumed in the Perry USAR Chapter 15 LOCA analysis, provide-additional analysis to show that the 10 CFR Part 100 whole body and l thyroid 2-hour and 30 day dose limits at the exclusion area boundary would not be exceeded.

3. Describe Perry Unit 1 MSIY experience with respect to maintenance induced defects discussed in your [[letter::PY-CEI-NRR-0982, Provides Addl Info & Commitment Re Request to Revise Tech Spec 3.6.1.2.c Concerning Main Steam Line (MSL) Leakage Limits.Util Will Keep Current Limit Below 200 Scfh for All MSLs & Commits to Administrative Limit on Individual MSLs|March 6,1989 letter]].

4. Provide the BWR Owner's Group data alluded to in your [[letter::PY-CEI-NRR-0982, Provides Addl Info & Commitment Re Request to Revise Tech Spec 3.6.1.2.c Concerning Main Steam Line (MSL) Leakage Limits.Util Will Keep Current Limit Below 200 Scfh for All MSLs & Commits to Administrative Limit on Individual MSLs|March 6,1989 letter]] which you ir.dicate supports leakage rates of 200 SCFH. a

5. You also indicate in your [[letter::PY-CEI-NRR-0982, Provides Addl Info & Commitment Re Request to Revise Tech Spec 3.6.1.2.c Concerning Main Steam Line (MSL) Leakage Limits.Util Will Keep Current Limit Below 200 Scfh for All MSLs & Commits to Administrative Limit on Individual MSLs|March 6,1989 letter]] that." industrial l experience suggests that, by attempting to correct non-existing or minimal defects in the valves, it is likely that some actual defects may be introduced that lead to later leak test failures". Describe the }

magnitude of the before and after repair leakages for all examples of this type.- Provide data on the percentage of maintenance induced failures experienced industry-wide.

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